Wealthfront 529 College Savings Plan Plan Description and Participation Agreement

Transcription

1 Wealthfront 529 College Savings Plan Plan Description and Participation Agreement September 30, 2016 Administered by Nevada State Treasurer Dan Schwartz Investment Products Offered Are Not FDIC Insured May Lose Value Are Not Guaranteed 1

2 Read this Plan Description carefully before you invest or send money. This Plan Description contains important information concerning the following topics: (i) fees and costs (See FEES AND EXPENSES ); (ii) investments and how and when the Board may change these (See PLAN RISKS AND DESIGNATED AND INDIVIDUAL PORTFOLIO RISKS Potential Changes to the Plan ); (iii) portfolio investment performance (See APPENDIX A: Historical Investment Performance ); (iv) federal and state tax considerations (See FEDERAL AND STATE TAX TREATMENT ); (v) risk factors (See PLAN RISKS AND DESIGNATED AND INDIVIDUAL PORTFOLIO RISKS ); and (vi) limitations or penalties imposed by the Plan upon transfers between investment options, transfers to other Nevada sponsored plans, transfers to other Section 529 Plans or non-qualified distributions generally (See FEDERAL AND STATE TAX TREATMENT ). i

3 Table of Contents PLAN HIGHLIGHTS...1 KEY TERMS...4 IMPORTANT NOTICES...7 INTRODUCTION...9 APPLICATION PROCESS...10 General...10 Account Application...10 Personal Information...10 Restrictions for Certain Accounts with Non-U.S. Addresses...11 Ownership Transfers...11 Designation of Successor Account Owner...11 Changing the Beneficiary...11 No Assignments or Pledges...12 Account Restrictions...12 CONTRIBUTIONS...13 Electronic Funds Transfer...13 Checks...13 Recurring Contributions...13 Rollover Contributions and Other Transfers...14 Rollovers...14 Plan Transfers for the Account of a New Beneficiary...14 Plan Transfers for the Same Beneficiary...14 Transfer into a Plan Account from Another Plan Within the Trust for the Benefit of a New Beneficiary...14 Transfer into a Plan Account from Another Plan Within the Trust for the Benefit of a Same Beneficiary...15 Re-contribution of Refunds from Eligible Educational Institutions...15 Maximum Contribution Limit...15 Excess Contributions...15 Contribution Policies and Fees...15 Control Over the Account...16 Pricing of Designated Portfolio Units...16 CONFIRMATIONS AND STATEMENTS...17 WITHDRAWALS...18 Procedures for Withdrawals...18 Qualified Withdrawals...18 Qualified Higher Education Expenses...18 Eligible Educational Institution...18 Refunds...18 Non-Qualified Withdrawals...19 Other Withdrawals...19 Residual Account Balances...20 FEDERAL AND STATE TAX TREATMENT Plans Generally...21 Important Tax Consideration Plan Contributions and Withdrawals...21 Qualified Rollovers...22 Other Contributions and Transfers...22 Coordination with Other Higher Education Expense Benefit Programs...22 Education Credits...22 Federal Gift and Estate Taxes...22 State Taxes...23 INVESTMENTS...24 FEES AND EXPENSES...26 Wealthfront Advisory Fee...26 Annual Asset-Based and Total Fees for Designated Portfolios...26

4 Table of Contents Individual Portfolio Fees by Glide Path...30 Certain Transaction Fees...32 PLAN RISKS AND DESIGNATED AND INDIVIDUAL PORTFOLIO RISKS...33 Wealthfront Advisory Risk...33 Risks of Investing in the Plan...33 No Guarantee of Principal or Earnings; No Insurance...33 Limited Investment Direction...33 Liquidity...33 Potential Changes to the Plan...34 Status of Federal and State Law and Regulations Governing the Plan...34 No Indemnification...34 Eligibility for Financial Aid...34 No Guarantee That Investments Will Cover Qualified Higher Education Expenses; Inflation and Qualified Higher Education Expenses...35 Education Savings and Investment Alternatives...35 No Guarantee of Admittance...35 Medicaid and Other Federal and State Benefits...35 Suitability and Education Savings Alternatives...35 Differences Between Performances of Designated Portfolios and Underlying ETFs...35 Differences Between Performances of Individual Portfolios and Designated Portfolios...36 Designated Portfolio Investment Risk...36 Individual Portfolio Investment Risk...36 OTHER INFORMATION...37 Arbitration...37 Electronic Communications and Disclosure Relating to Internet Access...37 Continuing Disclosure...38 Creditor Protection Under U.S. and Nevada Law...38 Independent Registered Public Accounting Firm...38 Custodial Arrangements...38 Tax Reporting...38 Conflicts...38 Contact Information...38 Privacy Statements...38 Investment Risk; No Guarantee...39 Tax Considerations...39 Individual Advice...39 Plan Description Information...39 Representations...40 APPENDIX A: INVESTMENTS... A-1 Investments... A-1 Historical Investment Performance... A-7 Profiles of Underlying ETFs... A-7 APPENDIX B: WEALTHFRONT 529 COLLEGE SAVINGS PLAN PARTICIPATION AGREEMENT...B-1 iii

5 Plan Highlights PLAN HIGHLIGHTS The information shown in the Plan Highlights is only a summary of the Plan. More detailed information about the Plan is described in the pages that follow. Please read this entire Plan Description before investing. Capitalized terms that are not otherwise defined have the meanings set forth in KEY TERMS below. Before you make contributions to the Plan, please read and understand this Plan Description and the Participation Agreement attached hereto as APPENDIX B. Please keep both this Plan Description and the Participation Agreement for future reference. These documents together give you important information about the Plan, including information about the investment risks associated with, and the terms under which you agree to participate in, Plan. Purpose of the Wealthfront 529 College Savings Plan To help individuals and families save for Qualified Higher Education Expenses through a tax-advantaged investment plan sponsored by the State of Nevada. The Wealthfront 529 College Savings Plan is established under Section 529 of the Code. The Plan is open to residents of any State. Who s who in the Wealthfront 529 College Savings Plan The State of Nevada sponsors the Plan, which is offered by the Trust. The Trust is administered by the Board, which is chaired by the Nevada State Treasurer. ABD serves as the Program Manager and, together with its affiliates, has overall responsibility for the day-to-day operations of the Plan and provides administration and recordkeeping services for the Plan. The Direct Program Management Agreement between ABD and the Board expires in Wealthfront serves as investment adviser and WBC serves as the distributor. Wealthfront also provides for certain marketing services for the Plan pursuant to an Operating Agreement that expires in 2021 and which can be extended until Wealthfront constructs your Individual Portfolio Wealthfront serves as your automated investment adviser. Under the Plan, Wealthfront constructs an Individual Portfolio for you using Designated Portfolio Units from up to nine Designated Portfolios, each of which contains a single underlying ETF. Wealthfront designs your Individual Portfolio to provide a diversified asset allocation based on your individual risk tolerance as reflected by your Risk Score, which is determined by your responses to a Risk Questionnaire. Using your Risk Score, Wealthfront assigns your Individual Portfolio to one out of 20 Glide Paths, each of which determines how your Individual Portfolio s allocations of Designated Portfolios will change over time. Each Glide Path gradually shifts the asset allocations of the Designated Portfolios in your Individual Portfolio to progressively decreasing levels of expected risk as your Beneficiary s Expected Matriculation Date approaches. Your starting point along the specific Glide Path is determined by the Beneficiary s Expected Matriculation Date. (See INVESTMENTS. ) Individual Advice No investment recommendation or advice received by the Account Owner from Wealthfront or any other person is provided by, or on behalf of, the State of Nevada, the Board, the Plan, or ABD or any of its affiliates. Differences between the Wealthfront 529 College Savings Plan and other 529 plans Unlike many other 529 Plans, your assets are not managed in a commingled fund structure. In a commingled fund structure, you buy a single fund. In this Plan, each Individual Portfolio is managed separately, and will be allocated to up to nine Designated Portfolios as prescribed by your Risk Score and your Beneficiary s Expected Matriculation Date. Contribution limits The minimum initial contribution is $500. Subsequent contributions must be at least $100. The current maximum contribution limit for all Plan Accounts for the same beneficiary under all 529 savings plans sponsored by the State of Nevada is $370,000. Although you can no longer contribute to an Account once this limit is reached, it may continue to grow through investment returns. Residency Requirements You do not have to be a resident of Nevada. You must simply be a U.S. citizen or resident alien. Beneficiary Age Limits None Your Beneficiary may be of any age, from newborn to adult. Tax Advantages In general, 529 college savings plans provide for federal tax deferred growth of investments; no federal income tax on qualified withdrawals; and no gift tax on contributions up to $70,000 ($140,000 for spouses electing to split gifts) pro-rated over five years and 1

6 Plan Highlights contributions are considered to be completed gifts for federal gift and estate tax purposes. There are no annual adjusted gross income limits. This Program Description does not contain legal or tax advice. You should consult your own tax advisor for more information. School Eligibility Investments may be used at any eligible postsecondary school in the United States or abroad. For a list of eligible schools, please visit Qualified Withdrawals The earnings portion of qualified withdrawals are federal income tax free if used to pay for Qualified Higher Education Expenses, including: tuition, books, supplies, fees, and equipment required for enrollment or attendance at an Eligible Educational Institution, room and board (with limitations), and expenses for the purchase of computer or peripheral equipment, computer software, or Internet access and related services, if such equipment, software, or services are to be used primarily by the Beneficiary during any of the years the Beneficiary is enrolled at an Eligible Educational Institution. (See FEDERAL AND STATE TAX TREATMENT. ) If your Beneficiary decides not to go to college You may change your Beneficiary to a new Beneficiary who is a Member of the Family of the original Beneficiary, and that transfer will not be subject to federal income tax or penalty. You also may make withdrawals from the Account or close the Account by notifying Wealthfront. Any non-qualified withdrawals will be subject to federal and state taxes as well as a 10% federal tax penalty on earnings. Fees and Expenses The estimated annualized Total Fee (including Underlying ETF Expense Ratio, Ascensus Program Management Fee, Wealthfront Advisory Fee and Board Fee) ranges from 0.43% to 0.46% of the assets in your Account depending on the asset allocation across the Designated Portfolios in your Individual Portfolio. (See FEES AND EXPENSES. ) Investments The investments in the Plan consist of nine Designated Portfolios, each of which contains one low-cost liquid ETF. Each Designated Portfolio is divided into Designated Portfolio Units, which Wealthfront uses as building blocks to construct Individual Portfolios based on your individual Risk Score. These Designated Portfolios Units are municipal fund securities issued by the Trust. The underlying ETF contained within each of the Designated Portfolios is an exchange-traded investment product registered with the SEC under the Investment Company Act of (See INVESTMENTS and APPENDIX A - Investments. ) Plan and Portfolio Risks You and your Beneficiary do not have access or rights to any assets of the State of Nevada or any assets of the Trust other than the assets credited to your Account for that Beneficiary. The Plan is an investment vehicle. Accounts in the Plan are subject to certain risks including: (i) the possibility that you may lose money over short or even long periods of time; (ii) the risk of changes in applicable federal and state tax laws and regulations; (iii) the risk of Plan changes including changes in fees and expenses; and (iv) the risk that contributions to the Plan may adversely affect the eligibility of the Beneficiary or you for financial aid or other benefits. Some Designated Portfolios carry more and/or different risks than others. You should weigh such risks with the understanding that they could arise at any time during the life of your Account. (See PLAN RISKS AND PORTFOLIO RISKS. ) No Guarantee When you contribute to the Plan, your money will be invested in Designated Portfolio Units. An investment in the Plan is not a bank deposit. None of your Account, the principal you invest, nor any investment return is insured or guaranteed by any Plan Official, the federal government, the Federal Deposit Insurance Corporation ( FDIC ), or any other governmental agency. Investment returns will vary depending upon the performance of the Designated Portfolios in your Account. You could lose all or a portion of your investment. Account Applications and Account Information You must complete an application online at Account Owners will receive periodic Account statements, transaction confirmations, and all other correspondence entirely online. Contact Information support@wealthfront.com or (650) Interests in the Plan are municipal fund securities issued by the Trust administered by the Board, which is chaired by the Nevada State Treasurer. The Plan, which is within the Trust, is administered by the Board. Interests in the Trust are sold exclusively by WBC. 2

7 Trust Interests (also known as Designated Portfolio Units) have not been registered with the Securities and Exchange Commission or any other state or federal governmental agency. Plan Highlights 3

8 Key Terms KEY TERMS Terms used in this Plan Description document have the following meanings: 529 Plan: A qualified tuition program established under and operated in accordance with Section 529 of the Code. ABD: Ascensus Broker Dealer Services, Inc., the Program Manager of the Plan. Account: An Account established in the Plan by you as the Account Owner. Account Application: An online application to be completed by you as the Account Owner to open an Account. By completing and submitting the Account Application, you agree to be bound by the terms and conditions of the Participation Agreement. Account Owner: The person or entity that establishes an Account and controls the assets held in the Account on behalf of a Beneficiary and any person or entity who is the successor in interest to such person or entity in accordance with the Act and Program Regulations. A non-entity Account Owner must be a natural person of legal age who is either a U.S. citizen or resident alien and has a valid Social Security number (or taxpayer identification number) with the authority to open an individual Account. An Account Owner is an investment advisory client of Wealthfront. ACSR: Ascensus College Savings Recordkeeping Services, LLC. Act: Chapter 353B of the Nevada Revised Statutes, as amended. AIA: Ascensus Investment Advisors, LLC. Ascensus College Savings: ABD and its affiliates, AIA and ACSR. Ascensus Program Management Fee: An 0.05% annualized fee based on the net market value of the Account charged by ABD for its program management services. Asset-Based Fee: The sum of the Underlying ETF Fees, the Ascensus Program Management Fee and the Board Fee. BlackRock: BlackRock Fund Advisors. Beneficiary: The individual designated by the Account Owner as the beneficiary of the Account at the time the Account is established or the individual who is designated as the new Beneficiary when the Beneficiary of an Account is changed. Board: The Board of Trustees of the College Savings Plans of Nevada, which is chaired by the Nevada State Treasurer and administers the Trust. Board Fee: A fee charged to each Designated Portfolio by the Board to pay for expenses related to oversight and administration of the Trust. If assets in the Plan are $5 billion or less, each Designated Portfolio will bear an annualized fee of 0.01% based on the assets in such Designated Portfolio that is used to pay the Board Fee. However, if assets in the Plan are less than $1 billion, the Board Fee will be an annual fixed fee equal to $100,000 and Wealthfront (not you as the Account Owner through your investment in a Designated Portfolio) will directly pay the portion of the Board Fee equal to the difference between the 0.01% annualized fee for all Designated Portfolios and the annual fixed fee of $100,000. If assets in the Plan are greater than $5 billion, the annualized fee borne by each Designated Portfolio will be reduced below 0.01% based on the assets in such Designated Portfolio such that the entire amount of the fees for all Designated Portfolios equals a fixed annual fee of $500,000, which is paid to the Board as the Board Fee. Code: United States Internal Revenue Code of 1986, as amended from time to time. There are references to various sections of the Code throughout the document, including Section 529 as it exists today and as it may subsequently be amended and regulations adopted under it. Designated Portfolio: A portfolio in the Plan that contains one ETF. The Plan has nine Designated Portfolios corresponding to nine ETFs, each representing a different asset class. Designated Portfolio Unit: The outstanding interests of Designated Portfolios are divided into Units. A Designated Portfolio Unit is a municipal fund security. Designated Portfolio Units are used as building blocks to construct the Individual Portfolios for each Account Owner. Also known as a Trust Interest. Direct Program Management Agreement: An agreement by and between the Board and ABD, as the Program Manager, to provide the Plan with administrative, Account servicing, marketing and promotion, and investment management services. The agreement between the Board and the Program Manager is now effective and will terminate in 2032, or earlier as provided in the Direct Program Management Agreement. 4

9 Key Terms Eligible Educational Institution: Generally, an institution as defined in the Code includes accredited post-secondary educational institutions in the United States or abroad offering credit toward an associate s degree, a bachelor s degree, a graduate level or professional degree, or another recognized postsecondary credential, and certain post-secondary vocational and proprietary institutions. The institution must be eligible to participate in U.S. Department of Education student financial aid programs. For a list of eligible schools, please visit EFT: Electronic funds transfer. ETF: Exchange traded fund. The underlying investments in the Plan are ETFs. Expected Matriculation Date: The date that your Beneficiary is expected to start attending an Eligible Educational Institution. Glide Path: A Glide Path represents a collection of asset allocations that automatically adjusts over time to decreasing levels of expected risk as the Expected Matriculation Date approaches. You as an Account Owner are matched to an optimized Glide Path based on your Risk Score, as determined by your executed Risk Questionnaire. Your starting point along the Glide Path is determined by the Expected Matriculation Date of your Beneficiary. Good Order: Good Order means that the Plan is able to validate a transaction (as determined by Wealthfront). For a contribution, Good Order also means that the EFT or check transaction, as applicable, has been effected such that the necessary funds are immediately available for investment by the Plan. Individual Portfolio: A portfolio of Designated Portfolio Units that are invested in accordance with an assigned Glide Path. Wealthfront creates an Individual Portfolio for each Account. Your Individual Portfolio is designed to be consistent with your risk tolerance as determined by your executed Risk Questionnaire. Assets in an Account are invested in accordance with your Individual Portfolio, which follows a Glide Path. In accordance with its assigned Glide Path, your Individual Portfolio automatically adjusts over time to decreasing levels of expected risk as the Expected Matriculation Date approaches. IRS: Internal Revenue Service. Maximum Contribution Limit: The Maximum Contribution Limit for the Plan is currently $370,000. For purposes of the Maximum Contribution Limit, balances for all accounts for the same Beneficiary under all 529 Plans sponsored by the State of Nevada are aggregated. The Maximum Contribution Limit is based on the aggregate market value of the Account(s) for a Beneficiary, and not solely on the aggregate contributions made to the Account(s). Member of the Family: For purposes of changing the Beneficiary, a member of the family of the Beneficiary is defined by the Code as: Father, mother, or an ancestor of either, Son, daughter, or a descendant of either, Stepfather or stepmother, Stepson or stepdaughter, Brother, sister, stepbrother, or stepsister, Brother or sister of the father or mother, Brother-in-law, sister-in-law, son-in-law, daughter-in-law, father-in-law, or mother-inlaw, Son or daughter of a brother or sister, Spouse of the Beneficiary or any of the individuals mentioned above, or First cousin. For purposes of this definition, a legally adopted child of an individual is treated as the child of such individual by blood and a half-brother or half-sister is treated as a brother or sister. NYSE: New York Stock Exchange. Operating Agreement: The agreement by and among ABD, ACSR, AIA, WBC and Wealthfront, pursuant to which Wealthfront offers the Plan. Participation Agreement: The written agreement between you as an Account Owner and the Board, substantially in the form approved by the Board. You as an Account Owner agree to the terms and conditions of the Participation Agreement by completing and submitting an Account Application. Plan: The Wealthfront 529 College Savings Plan. Plan Officials: The State of Nevada, the Nevada State Treasurer, staff of the Nevada State Treasurer s Office, the Plan, the Board, the Trust, any other agencies, instrumentalities or funds of the State of Nevada, the Program Manager, Wealthfront and each of their respective affiliates, officials, officers, directors, employees and representatives. Program: The College Savings Plans of Nevada. The Plan is within the Program. Program Manager: ABD serves as the Plan s Program Manager and has overall responsibility for the day-to-day operations of the Plan. Program Regulations: Regulations adopted and amended from time to time by the Board or the Nevada State Treasurer pursuant to the Act. 5

10 Key Terms Qualified Higher Education Expenses: Expenses include tuition, fees, and the cost of books, supplies, and equipment required for the enrollment or attendance of a Beneficiary at an Eligible Educational Institution (including expenses for special needs services in the case of a special needs Beneficiary that are incurred in connection with such enrollment or attendance), along with certain room and board expenses of a Beneficiary attending school at least half-time, as allowable under Section 529, and expenses for the purchase of computer or peripheral equipment (as defined in section 168(i)(2)(B) of the Code), computer software (as defined in section 197(e)(3)(B) of the Code), or Internet access and related services, if such equipment, software, or services are to be used primarily by the Beneficiary during any of the years the Beneficiary is enrolled at an Eligible Educational Institution. Risk Questionnaire: The series of questions set forth in the Account Application process used by Wealthfront to evaluate your risk tolerance, i.e., both your objective capacity to take risk in investing and your subjective willingness to take risk in investing. For example, if you have greater excess income, you have a higher objective capacity to take risk than if you had lesser excess income, and if you are more tolerant of a higher level of uncertainty of investment performance than another Account Owner for the same uncertainty of investment performance, you have a greater subjective willingness to take investment risk. Risk Score: A value from 0.5 to 10, expressed in increments of 0.5 (i.e., a total of 20 possible values), that Wealthfront assigns to you based on your answers to the Risk Questionnaire that represents your risk tolerance. A lower Risk Score indicates a lower capacity and willingness to take investment risk, and a higher Risk Score indicates a higher capacity and willingness to take investment risk. Section 529: Section 529 of the Code, as amended from time to time, and any regulations and other guidance issued thereunder. Terminal Funding Ratio: The ratio of (A) value of your Individual Portfolio to (B) the present value of the total cost for the Beneficiary to attend an Eligible Educational Institution, both at the Expected Matriculation Date. Total Fee: The sum of the Underlying ETF Fees, the Ascensus Program Management Fee, the Board Fee and the Wealthfront Advisory Fee. Trust: The Nevada College Savings Trust Fund. Trust Interests: Municipal fund securities, which are issued by the Trust in exchange for contributions. Designated Portfolio Units are Trust Interests. Underlying ETF Fee: For each Designated Portfolio, the expenses charged by the ETFs underlying such Designated Portfolio. Vanguard: The Vanguard Group, Inc. WBC: Wealthfront Brokerage Corporation. Wealthfront: Wealthfront Inc. Wealthfront Advisory Fee: A 0.25% annualized fee based on the net market value of an Account charged by Wealthfront for its investment advisory services in connection with the Plan. Currently, Wealthfront waives its investment advisory fees for the first $10,000 of assets in any Wealthfront investment advisory account(s) including Accounts in the Plan. In addition, for Nevada residents who open an Account, Wealthfront will waive its investment advisory fees for an additional $15,000 of assets ($25,000 of assets in total) in your Wealthfront account(s) in and outside of the Plan in the aggregate. Thus, by opening an Account, a Nevada resident will increase the waiver of his or her Wealthfront investment advisory fees from the first $10,000 of assets under management with Wealthfront to the first $25,000 of assets under management. You: References in this document to you means you in your capacity as the Account Owner. 6

11 Important Notices IMPORTANT NOTICES Administration Interests in the Plan are municipal fund securities issued by the Trust administered by the Board, which is chaired by the Nevada State Treasurer. The Plan, which is within the Trust, is administered by the Board and is managed by the Program Manager. Trust Interests, also known as Designated Portfolio Units, are sold exclusively by WBC. Trust Interests are not guaranteed by the State of Nevada, the Board or any other governmental entities, or Wealthfront or Ascensus or any of their respective affiliates. Tax Considerations Depending upon the laws of your home state or the home state of the Beneficiary, favorable state tax treatment or other benefits offered by that home state for investing in 529 college savings plans may be available only if you invest in the home state s college savings plan. Because different states have different tax provisions, this Plan Description contains limited information about the state tax consequences of investing in the Plan. Therefore, you should consult with your own financial, tax, or other adviser to learn more about how state-based benefits (including any limitations) would apply to your specific circumstances. You also may wish to contact your home state s 529 Plan(s), or any other 529 Plan, to learn more about those plans features, benefits and limitations. Keep in mind that any state-based benefit offered with respect to a particular 529 college savings plan should be one of many appropriately weighted factors to be considered in making an investment decision. Tax Disclaimer 529 Plans are intended to be used only to save for Qualified Higher Education Expenses. 529 Plans are not intended to be used, nor should they be used, by any taxpayer for the purpose of evading federal or state taxes or tax penalties. Taxpayers may wish to seek tax advice from an independent tax advisor based on their own particular circumstances. Individual Advice Wealthfront is your automated investment adviser. No investment recommendation or advice received by you from Wealthfront or any other person is provided by, or on behalf of, the State of Nevada, the Board, the Plan, or Ascensus. Plan Description Information The information in this Plan Description is believed to be accurate as of the cover date but is subject to change without notice. You should rely only on the information contained in this Plan Description and any supplements to the Plan Description. No one is authorized to provide information that is different from the information in the most current form of this Plan Description. Statements contained in this Plan Description that involve estimates, forecasts, or matters of opinion, whether or not expressly so described herein, are intended solely as such and are not to be construed as representations of facts. This Plan Description does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of a security in the Plan by any person in any jurisdiction in which it is unlawful for such person to make such an offer, solicitation, or sale. Special Considerations The Board reserves the right to: Refuse, change, discontinue, or temporarily suspend Account services including accepting contributions and processing distribution requests, for any reason. Delay sending out the proceeds of a distribution request for up to seven calendar days (this generally applies only to very large redemptions without notice or during unusual market conditions). Suspend or postpone payment of the proceeds of distribution requests when the NYSE is closed for any reason other than its usual weekend or holiday closings, when the SEC restricts trading, or when any emergency circumstances exist. Change the Plan s fees and charges. Add, subtract, terminate, or merge Designated Portfolios, or the underlying funds in which any Designated Portfolio invests. Terminate an Account if the Board determines that the Account Owner or the Beneficiary has provided false or misleading information to the Board, the Program Manager, or Wealthfront. Add a new, or replace the current, Program Manager. 7

12 Important Notices Under the Direct Program Management Agreement between Ascensus and the Board (which expires in 2032 and may be terminated sooner under certain circumstances, including in response to a material breach of the contract by either Ascensus or the Board, after providing notice and an opportunity to cure, or in the event the Board is no longer authorized to administer 529 plans including the Plan as a result of any legislation or regulation changes), the Board may hire new or additional entities in the future to manage all or part of the Plan s assets. Read this Plan Description and Participation Agreement carefully before you invest or send money. This Plan Description contains information you should know before participating in the Plan, including information about fees and risks. Neither the SEC nor any state securities commission has approved or disapproved these securities or passed upon the adequacy of this Plan Description. Any representation to the contrary is a criminal offense. 8

13 Introduction INTRODUCTION The Trust is administered by the Board, which is chaired by the Nevada State Treasurer. The Plan is also administered by the Board, and is designed to satisfy the requirements of the Code, and any regulations and other guidance issued there under. The Plan is designed as a savings vehicle for Qualified Higher Education Expenses. Account Owners purchase Trust Interests to save for college expenses and other qualified higher education. This Plan Description addresses only the Plan and not any other 529 Plan within the Trust. As Program Manager for the Plan, ABD with its affiliates has overall responsibility for the day-to-day operations of the Plan and provides administration and recordkeeping services for the Plan. Wealthfront serves as investment adviser and WBC the distributor for the Plan and also provides for certain marketing services for the Plan. Wealthfront, your investment adviser, is an automated investment service registered with the SEC. As a provider of automated investment services, Wealthfront is frequently referred to as an automated investment adviser. Automated investment advisers are a class of financial advisers that provide portfolio management online with minimal human intervention. Wealthfront employs algorithms based on modern portfolio theory that has served the traditional advisory community. Wealthfront currently manages over $3 billion dollars (unaudited) in client assets through its automated investment service as of March 31, The investments in the Plan consist of nine Designated Portfolios, each of which contains one low-cost liquid ETF. Wealthfront uses the nine Designated Portfolios Units as building blocks to construct an Individual Portfolio for you based on your individual Risk Score and your Beneficiary s Expected Matriculation Date. Designated Portfolios Units are municipal fund securities issued by the Trust. You should consider the structure of the Plan and the different investment strategies and risks of the Plan and the underlying ETFs in the Designated Portfolios before opening an Account. For more detailed information about the Plan s investments, please see INVESTMENTS and APPENDIX A. In addition to the Plan, the Board also sponsors the other college savings plans with other investment managers, as well as the Nevada Prepaid Tuition Plan. This Plan Description relates only to the Wealthfront 529 College Savings Plan. The other Plans administered by the Board (i) may offer different benefits or different investment options with different investment advisors, (ii) may be marketed or sold differently, and (iii) may assess different fees, withdrawal penalties, and/or sales charges. Information regarding other Nevada college savings Plans or the Prepaid Tuition Plan may be obtained from the Office of the Nevada State Treasure at or Contact information for the College Savings Trust of Nevada is 555 E. Washington Avenue, Suite 4600, Las Vegas, NV or

14 Application Process APPLICATION PROCESS General To participate in the Plan, an Account Owner must either be (i) a natural person at least 18 years of age who is a U.S. citizen or resident alien and has a valid Social Security number (or taxpayer identification number), with the authority to open an individual Account or (ii) a legal entity such as a trust that is permitted to open an Account. You must complete and sign an Account Application online, and any other documents required by the Plan for an Account to be established. If you are opening an Account as a trust, you must include copies of the pages of the trust agreement containing the name of the trust, the date of the trust, and a listing of all trustees and their signatures. There are no state residency requirements or income level restrictions to open an Account. There is no enrollment fee or charge to establish an Account. Before investing in a 529 Plan, you should consider whether the state(s) where you or the Beneficiary live or pay state income tax sponsors a 529 plan that offers you or the beneficiary state income tax or other benefits not available to you or the beneficiary through the Plan. Investors should consider the structure of the Plan and the different investment strategies employed by and risks of the Designated Portfolios before opening an Account. Account Application You must complete the Account Application online at At the time of enrollment, you must designate a Beneficiary whose Qualified Higher Education Expenses are expected to be paid from the Account. Accounts will not be established until Wealthfront accepts a properly completed Account Application. There may only be one Account Owner and one Beneficiary per Account. You may establish only one Account for a particular Beneficiary. The Beneficiary is not required to be related to you. You may have multiple Accounts for different Beneficiaries. Also, different Account Owners may have Accounts for the same Beneficiary within the Plan. You may name a successor Account Owner to assume control of the Account in the event of your death. A valid Social Security number (or taxpayer identification number) and date of birth must be provided for you and the Beneficiary. At the time of enrollment, you will be required to complete and execute a Risk Questionnaire designed to assess your risk tolerance. The Risk Questionnaire serves as the guide to Wealthfront s automated investment service on how to construct your Individual Portfolio. You complete the Risk Questionnaire via the Account Application process, and Wealthfront uses it to assign you a Risk Score based on scale of 0.5 to 10 in increments of 0.5, i.e., one of 20 different Risk Scores. Your completion of the Risk Questionnaire is mandatory. The Risk Questionnaire is designed to jointly assess your objective capacity to bear risk (e.g., your after-tax income) as well as your subjective willingness to bear risk (e.g., your anticipated reaction to a decline in the value of your Individual Portfolio). Based on the Risk Score, Wealthfront assigns your Individual Portfolio to one of the 20 Glide Paths, each of which reflects a different balance of expected returns and expected risks. Wealthfront deems Account Owners with higher Risk Scores more risktolerant and applies a lower priority for certainty of the Terminal Funding Ratio. Therefore, Wealthfront assigns these Account Owners to Glide Paths that are characterized by greater expected returns and expected risks. Wealthfront deems Account Owners with lower Risk Scores to be less risk-tolerant and applies a higher priority for certainty of the Terminal Funding Ratio. Therefore, Wealthfront assigns these Account Owners to Glide Paths that are characterized by lower expected returns and expected risks than those Account Owners with higher Risk Scores. You have the opportunity to select a Risk Score that differs from this recommendation. If you select a Risk Score that is higher than the recommended Risk Score by 2.0 or more points, you are required to subsequently re-confirm the change. You can also subsequently update your Risk Scores to reflect new circumstances affecting your risk tolerance, such as having an additional child or being promoted to a significantly higher-paying job. However, you can only make changes up to two times per calendar year or upon a change of the Beneficiary. Personal Information Both the Program Manager and Wealthfront act in accordance with a customer identification program required by federal law, including the USA PATRIOT Act, and obtain certain information from you in order to verify your identity. You are required to provide the following information as requested on the Plan s Account Application: 1. Full name of you and the Beneficiary; 2. Date of birth of you and the Beneficiary; 3. Social Security number (or taxpayer identification number) of you and the Beneficiary; and 4. Your permanent/ physical street address. 10

15 Application Process Wealthfront may refuse to open an Account if the above-referenced information is not provided. If reasonable efforts to verify this information are unsuccessful, Wealthfront may take certain actions regarding the Account without prior notice to you, including among others, rejecting contribution and transfer requests, suspending Account services, or closing the Account. Designated Portfolio Units redeemed as a result of closing an Account will be valued at the net asset value next calculated after Wealthfront decides to close the Account, and the risk of market loss, tax implications and any other expenses as a result of the liquidation, will be solely your responsibility. Restrictions for Certain Accounts with Non-U.S. Addresses The Trust Interests are only available for sale in U.S. states and certain other areas subject to U.S. jurisdiction, and the Trust Interests may not be offered for sale in non-u.s. jurisdictions. You are required to maintain a legal U.S. physical address (and mailing address, if different from the physical address) in order to open an Account. Most, but not all, Air/Army Post Office (APO), Fleet Post Office (FPO), or Diplomatic Post Office (DPO) addresses are considered U.S. addresses. Once your Account is opened, if either the mailing or physical address used in connection with the Account is changed to a non- U.S. address (excluding most APO, FPO, or DPO addresses), restrictions will be placed on the Account. The restrictions will not limit your ability to redeem Trust Interests, but such restrictions will limit (and may prohibit) your ability to make additional purchases of Trust Interests, including any additional purchases scheduled as part of a recurring investment plan. Ownership Transfers As an Account Owner, you may transfer ownership of an Account, without penalty, to another individual or entity to be the Account Owner in the Plan. A transfer of ownership of an Account does not require a change of the Beneficiary. A transfer of ownership of an Account will only be effective if it is irrevocable and transfers all rights, title, interest and power over the Account. A change in ownership of an Account may have negative income or gift tax consequences, so contact your tax advisor before transferring ownership of an Account. To transfer ownership of an Account, complete and submit the requisite online form to Wealthfront or contact Wealthfront at support@wealthfront.com or (650) Designation of Successor Account Owner You, except for you in your capacity as trustee of a trust, may designate a successor Account Owner (to the extent permissible under applicable law) to succeed to all of your rights, title, and interest in an Account (including, without limitation, the right to change the Beneficiary) upon your death. Such designation must either be on the original Account Application or submitted separately online. A successor Account Owner designation is not effective until it is received in Good Order by Wealthfront and processed by the Program Manager. You may revoke or change the designation of a successor Account Owner at any time by completing and submitting the requisite online form to Wealthfront or contacting Wealthfront at support@wealthfront.com or (650) Please review or contact Wealthfront at support@wealthfront.com or (650) for information needed to complete the change of ownership upon succession. You should consult a tax advisor regarding tax issues that might arise on a transfer of Account Ownership by succession. Changing the Beneficiary Section 529 generally allows for changes of the Beneficiary without adverse federal income tax consequences, as long as the new Beneficiary is a Member of the Family of the current Beneficiary. In addition, the proposed IRS regulations provide that no federal gift tax or generation-skipping transfer tax will result, as long as the new Beneficiary is of the same generation as the current Beneficiary. Any change of the Beneficiary to a person who is not a Member of the Family of the current Beneficiary is treated as a non-qualified withdrawal subject to applicable federal and state income taxes, as well as the additional 10% federal tax on earnings. To initiate a change of Beneficiary, you may do so online at The change will be made upon the Plan s receipt of the request in Good Order. The Plan reserves the right to suspend the processing of Beneficiary transfers if it suspects that such transfers are intended to avoid the Plan s Risk Score change limits. There is no fee or charge for changing a Beneficiary. Upon a change in the Beneficiary, assets will be invested in accordance with the allocations of the Glide Path on an Account as determined by your Risk Score and the new Beneficiary s Expected Matriculation Date. You may change your Risk Score when changing the Beneficiary for an Account. The change may result in a loss in the value of the 11

16 Application Process Account depending on market fluctuations during the time of the change. No Assignments or Pledges Neither an Account nor any portion thereof may be assigned, transferred or pledged as security for a loan (including, but not limited to, a loan used to make contributions to the Account) or otherwise by either you or the Beneficiary, except for changes of Beneficiary, qualified rollovers, as described below, and the transfer of Account Ownership to a successor Account Owner. Any pledge of an interest in an Account will be of no force and effect. Account Restrictions In addition to rights expressly stated elsewhere in this Plan Description, the Plan reserves the right to: freeze an Account and/or suspend Account services when the Plan has received reasonable notice of a dispute regarding the assets in an Account, including notice of a dispute in Account ownership or when the Plan reasonably believes a fraudulent transaction may occur or has occurred; freeze an Account and/or suspend Account services upon the notification to the Plan of the death of an Account Owner until the Plan receives required documentation in Good Order and reasonably believes that it is lawful to transfer Account ownership to the successor Account Owner; redeem an Account, without the Account Owner s permission, in cases of threatening conduct or suspicious, fraudulent or illegal activity; and reject a contribution for any reason, including contributions for the Plan that the Program Manager, Wealthfront or the Board believe are not in the best interests of the Plan, a Designated Portfolio or the Account Owners. The risk of market loss, tax implications, penalties, and any other expenses, as a result of such an Account freeze or redemption will be solely the Account Owner s responsibility. 12

17 Contributions CONTRIBUTIONS The minimum initial investment in the Plan is $500 per Account. Any additional contributions must be at least $100 per Account. In the future, the minimum initial contribution to the Plan may be higher or lower (or may be waived from time to time) and is subject to change at any time by the Board. You also may elect to sign up to make recurring contributions. Subsequent contributions to an Account will be invested in accordance with the Glide Path on an Account as determined by your Risk Score and Beneficiary s Expected Matriculation Date on file. You can make contributions by EFT or any other method approved by the Plan. Account Owners will receive confirmation via or other electronic means confirming all initial and subsequent contributions. Electronic Funds Transfer You may authorize Wealthfront or its designated agent to withdraw funds by EFT from a checking or savings account, subject to certain processing restrictions, for both initial and/or subsequent contributions to Accounts provided that you have submitted certain information about the bank account from which the money will be withdrawn. EFT transactions can be completed through the following means: (i) by submitting EFT instructions after enrollment, online at or (ii) by contacting support@wealthfront.com or (650) to initiate an EFT. The Plan may place a limit on the total dollar amount per day the Account Owner may contribute to an Account by EFT. Contributions in excess of such limit will be rejected. If you plan to contribute a large dollar amount to your Account by EFT, you may want to contact a client service representative at support@wealthfront.com or (650) to inquire about the current limit prior to making your contribution. Purchase requests that are received in Good Order by the Plan before 4 p.m. Eastern time on a business day will be given a trade date of the same business day of the date of receipt and will be effected at that business day s closing price for the applicable Designated Portfolio Units. Due to processing times involved with EFTs, one or more business days may elapse between the time you initiate an EFT before your purchase request will be considered to be in Good Order. Purchase requests that are received by Wealthfront in Good Order by the Plan after 4 p.m. Eastern time on a business day will be given a trade date of the next business day after the date the request is received and will be effected at that next business day s closing price for the applicable Designated Portfolio Units. If your EFT contribution cannot be processed because the bank account on which it is drawn contains insufficient funds, because of incomplete information or inaccurate information, or if the transaction would violate processing restrictions, the Plan reserves the right to suspend processing of that and future EFT contributions. As a result of federally mandated processing requirements for ACH transactions, the Plan will not facilitate contributions and distributions via an EFT involving a bank or other financial services company, including any branch of office thereof, located outside the territorial jurisdiction of the United States. Checks Although EFT is strongly preferred, contributions also may be made by check. Contributions made by check must be written in U.S. dollars and drawn on a U.S. bank. The check should be made payable and mailed according to instructions on Contributions may not be made by cash, money order, travelers checks, starter checks, credit card or bank courtesy checks, instant loan checks, third-party checks in an amount greater than $10,000, checks dated earlier than 180 days from the date of receipt, or any other instruments the Plan deems unacceptable. No stocks, securities, or other noncash assets will be accepted as contributions. Recurring Contributions You may contribute to your Account by authorizing Wealthfront to receive periodic automated debits from a checking or savings account at your bank, if your bank is a member of the Automated Clearing House, subject to certain processing restrictions. To initiate a recurring contribution during enrollment, you may complete the recurring contribution form after completion of the Account Application. You also may establish a recurring contribution online after an Account has been established. The Plan does not assess a charge for establishing recurring contributions. Your bank account will be debited on the day you designate, provided the day is a regular business day and the debit request can reasonably be processed by the Program Manager on such day. If such day is not a regular business day, then the Program Manager will attempt to process the debit request at the next regular business day. 13

18 Contributions Authorization to perform recurring contributions will remain in effect until the Plan has received notification of its termination. To be effective, a change to, or termination of, a recurring contribution must be received by Wealthfront at least five (5) business days before the next recurring contribution debit is scheduled to be deducted from your bank account. If your recurring contribution cannot be processed because the bank account on which it is drawn lacks sufficient funds or because of incomplete or inaccurate information, or if the transaction would violate processing restrictions, the Plan reserves the right to suspend processing of that and future recurring contributions. Rollover Contributions and Other Transfers You may make contributions to an Account with: Proceeds from the withdrawal of assets held in another state s 529 Plan (a Rollover ), Proceeds from the withdrawal of assets held in an Account in the Plan (a Plan Transfer ) for the benefit of a different Beneficiary, or Proceeds from the withdrawal of assets held in an account in another 529 Plan within the Trust (i.e., another Section 529 Plan offered by the State of Nevada) for the benefit of a different Beneficiary. Rollovers You may make a Rollover contribution without imposition of federal income tax or the additional 10% federal tax if such Rollover is made within 60 days of distribution from the originating account into an account for a new Beneficiary who is a Member of the Family of the original Beneficiary. A Rollover contribution to the Plan for the benefit of the same Beneficiary may be effected without adverse tax consequences only if no other such Rollovers have occurred with respect to such Beneficiary within the prior 12 months and if the Rollover contribution is made within 60 days of distribution from the originating account. Incoming rollovers can be direct or indirect. Direct rollovers involve the transfer of money from one 529 Plan directly to another. Indirect rollovers involve the transfer of money from an account in another state s 529 Plan to the Account Owner, who then contributes the money to an Account in the Plan. To avoid penalties and federal income tax consequences, money received by an Account Owner in an indirect rollover must be contributed to the Plan within 60 days of the distribution. In addition, there may be state income tax consequences (and in some cases state-imposed penalties) resulting from a rollover out of a state s 529 Plan. For direct rollovers, follow online instructions at or contact (650) If you plan to make an indirect rollover, contact a client service representative at support@wealthfront.com or (650) to inquire about the process, receive guidance and to provide the necessary information about your account at the other state s 529 Plan, including all requisite tax information such as the earnings component of the rollover in order to avoid negative tax consequences from failing to provide the requisite tax information in a rollover. Plan Transfers for the Account of a New Beneficiary You may make a Plan Transfer to an Account for the benefit of a new Beneficiary without imposition of federal income tax or the additional 10% federal tax, if such Plan Transfer is made directly into an Account for a new Beneficiary who is a Member of the Family of the original Beneficiary. To make such a transfer, follow online instructions at or contact (650) Plan Transfers for the Same Beneficiary You may make a transfer within the Plan for the benefit of the same Beneficiary. If the funds are transferred directly between Accounts online, the transfer will be treated as a nontaxable investment reallocation allowable up to two times per calendar year rather than as a tax-free rollover or transfer. To make such a transfer, follow online instructions at or contact (650) However, if you take a distribution (i.e., receives a withdrawal check from the transferring Account), the withdrawal will be treated as a nonqualified withdrawal subject to federal and applicable state income tax and the additional 10% federal tax on earnings. Transfer into a Plan Account from Another Plan Within the Trust for the Benefit of a New Beneficiary You may make a transfer to an Account with funds from an account in another plan within the Trust (i.e., another Section 529 Plan offered by the State of Nevada) for the benefit of a new Beneficiary without imposition of federal income tax or the additional 10% federal tax, if such transfer is made into an Account for a new Beneficiary who is a Member of the Family of the original Beneficiary. 14

19 Contributions If you plan to make a transfer into a Plan Account from another Plan within the Trust, you should contact a client service representative at support@wealthfront.com or (650) to inquire about the process, receive guidance and to provide the necessary information about your account at the other state s 529 Plan, including all requisite tax information such as earnings. Transfer into a Plan Account from Another Plan Within the Trust for the Benefit of a Same Beneficiary A transfer into an Account from another 529 Plan account within the Trust (i.e., another Section 529 Plan offered by the State of Nevada) for the benefit of the same Beneficiary will be treated as a nontaxable investment reallocation allowable up to two times per calendar year rather than as a tax-free Rollover or transfer. If you plan to make a transfer into a Plan Account from another Plan within the Trust, you should contact a client service representative at support@wealthfront.com or (650) to inquire about the process, receive guidance and to provide the necessary information about your account at the other state s 529 Plan, including all requisite tax information such as earnings. Re-contribution of Refunds from Eligible Educational Institutions If the Beneficiary receives from an Eligible Educational Institution a refund of funds originally withdrawn from an Account to pay for Qualified Higher Education Expenses, such funds may be recontributed to an account in a 529 Plan for the same Beneficiary up to the amount of the refund provided that the re-contribution is made within 60 days of the date of the refund. Such funds also will not be subject to federal income tax or the additional 10% federal tax. For tax purposes, you are responsible for maintaining proper documentation evidencing the refund from the Eligible Educational Institution. Maximum Contribution Limit You may continue to make contributions to an Account for a Beneficiary so long as the aggregate balance of all 529 Plan accounts for the same Beneficiary under all 529 Plans sponsored by the State of Nevada under the Act does not exceed the Maximum Contribution Limit, which is currently $370,000. Accounts that have reached the Maximum Contribution Limit will continue to accrue earnings, although future contributions may not be made to such Accounts. The Maximum Contribution Limit is based on the aggregate market value of the Account(s) for a Beneficiary and not solely on the aggregate contributions made to the Account(s). If, however, the market value of such Account(s) falls below the Maximum Contribution Limit due to market fluctuations and not as a result of withdrawals from such Account(s), additional contributions may be accepted by the Plan for the Account(s). The Plan may, in its discretion, refuse to accept a contribution upon determination that acceptance of such contribution would not comply with federal or state requirements. None of the Plan Officials will be responsible for any loss, damage, or expense incurred with a rejected or returned contribution. The Board is required to set the Maximum Contribution Limit for all accounts for a Beneficiary. The Board expects to evaluate the Maximum Contribution Limit annually but reserves the right to make adjustments more or less frequently. Information concerning the current Maximum Contribution Limit may be obtained through the Plan. It is possible that federal law might impose different limits on maximum allowable contributions in the future. Excess Contributions The Plan will not accept any contribution to the extent it would cause the Account balance to exceed the Maximum Contribution Limit ( Excess Contributions ). Excess Contributions, all or a portion of, will be rejected and returned to the contributor. If a contribution is applied to an Account and later determined by the Plan to have caused the aggregate market value of the Account(s) for a Beneficiary to exceed the Maximum Contribution Limit, the Plan will refund such Excess Contribution, and any earnings thereon, to the contributor. Any refund of an Excess Contribution may be treated as a non-qualified withdrawal. Contribution Policies and Fees Contributions made by checks, recurring contribution or EFT will not be available for withdrawal for seven (7) business days. Wealthfront may impose a fee on any recurring contribution or purchase via EFT that are cancelled due to insufficient funds at the funding source, or check returned unpaid by the financial institution upon which it is drawn, which fee may be deducted from the Account Owner s Account. (See FEES AND EXPENSES. ) The Plan uses reasonable procedures to confirm that transaction requests are genuine. You may be 15

20 Contributions responsible for losses resulting from fraudulent or unauthorized instructions received by the Plan, provided the Plan reasonably believes the instructions were genuine. To safeguard your Account, you are advised to keep confidential information concerning your Account. Contact Wealthfront immediately at or (650) if you believe there is a discrepancy between a transaction requested and the confirmation statement received or if you believe someone has obtained unauthorized access to your Account. Contributions may be refused if they appear to be an abuse of the Plan. Contributions to the Plan are invested in accordance with the investment policy established by the Board. The Board reserves the right to change the investment policy for the Plan at any time, without prior notice. Control Over the Account Although any individual or entity may make contributions to an Account, you, as the Account Owner, retain control of all contributions made to an Account as well as all earnings credited to the Account up to the date they are directed for withdrawal. A Beneficiary who is not the Account Owner has no control over any of the Account assets. Only you, as the Account Owner, will receive confirmation of Account transactions. Individuals or entities other than you that contribute funds to an Account will have no subsequent control over the contributions; you control all contributions made to an Account as well as all earnings credited to the Account. Only you, as the Account Owner, may direct transfers, rollovers, investment changes (as permitted under federal law), withdrawals and changes in the Beneficiary. Pricing of Designated Portfolio Units Interests in the Designated Portfolios are issued in Designated Portfolio Units. The value of each Designated Portfolio Unit is calculated each business day after the close of trading on the NYSE. The value is determined by dividing the dollar value of the Designated Portfolio s net assets (i.e., total Designated Portfolio assets minus total Designated Portfolio liabilities) by the number of Designated Portfolio Units for that Designated Portfolio outstanding. On holidays or other days when the NYSE is closed, the Designated Portfolio Unit values are not calculated, and the Plan does not transact purchase, exchange, transfer, or redemption requests. When an Account Owner purchases, redeems, or exchanges Designated Portfolio Units in the Account Owner s Account, the Account Owner will do so at the value of the Designated Portfolio s Units on the trade date. The trade date will be determined as follows: Transaction requests that are received in Good Order by the Plan before 4 p.m. Eastern time on a business day will be given a trade date of that same business day, and Designated Portfolio Units involved in that transaction will be given that business day s Designated Portfolio Unit value. Transaction requests that are received in Good Order by the Plan after 4 p.m. Eastern time on a business day will be given a trade date of the next business day, and Designated Portfolios Units involved in that transaction will be given the next business day s Designated Portfolio Unit value. 16

21 Confirmations and Statements CONFIRMATIONS AND STATEMENTS The Plan is administered online and all plan confirmations and statements will be delivered via or other electronic means. You will receive monthly and annual statements to reflect financial transactions via delivery or other electronic means. These transactions include: (1) contributions made to your Account; (2) withdrawals made from your Account; (3) contributions made by recurring contribution transactions; or (4) if applicable, transaction, advisory and maintenance fees incurred by the Account. The total value of your Account at the end of the month (year) will also be included in your monthly (annual) statements. You may access your monthly and/or annual statement(s) online at Confirmations will be sent by or other electronic means for any activity in your Account, except for recurring contribution transactions, and if applicable advisory and maintenance fees; instead these transactions will appear on your monthly and/or annual statement. Further, if permitted by applicable securities laws, rules and regulations, a separate confirmation for each transaction will not be sent, but rather all such transactions will appear on your monthly and/or annual statement. If you receive a confirmation that you believe contains an error or does not accurately reflect your authorized instructions e.g., the amount invested differs from the amount contributed you must promptly notify the Plan of the error. If you do not notify the Plan promptly, you will be considered to have approved the information in the confirmation and to have released the Plan Officials from all responsibility for matters covered by the confirmation. Neither the Plan nor any of the Plan Officials will be responsible for losses resulting from an error if such error resulted from fraudulent or unauthorized instructions received by the Plan that we reasonably believed were genuine. You agree to provide all information that the Board, the Program Manager or Wealthfront may need to comply with any legal reporting requirements. You should regularly review your Account statements and transaction confirmations. 17

22 Withdrawals WITHDRAWALS You may make withdrawals from your Account(s) or terminate your Account(s) in the Plan at any time by notifying the Plan. Upon a withdrawal or termination, the amount of the withdrawal is calculated at the Designated Portfolio Unit net asset value next determined after the Plan s receipt and processing of the request in Good Order. Procedures for Withdrawals Except for advisory and maintenance fees incurred by the Account, only you, as the Account Owner, may direct withdrawals from your Account. To make a withdrawal from an Account, you must request a withdrawal online and provide such other information or documentation as the Plan may require from time to time. The withdrawal request will generally be processed from the Account within three (3) business days of acceptance of the request. During periods of market volatility and at year-end, withdrawal requests may take up to five (5) business days to process. Please allow ten (10) business days for the proceeds to reach you. The frequency of withdrawals in a single month may be limited. A minimum withdrawal amount also may be established by the Plan. Withdrawals will be paid to the Account Owner, Beneficiary or Eligible Educational Institution by following the online instructions or by contacting Wealthfront at support@wealthfront.com or (650) for assistance. Payments to the Account Owner can be either by ACH or wire transfer, but payments to the Beneficiary or Eligible Educational Institution can only be made by check. Withdrawals may be subject to federal and/or state tax withholding. Under federal law, the earnings portion of non-qualified withdrawals will be subject to federal and any applicable state taxes and, unless an exception applies, to an additional 10% federal tax on earnings. (See FEDERAL AND STATE TAX TREATMENT. ) For purposes of determining whether a withdrawal is taxable or subject to the 10% additional tax, you must determine whether the withdrawal is made in connection with the payment of Qualified Higher Education Expenses, as defined under the Code and discussed below, or fits within one of the exceptions to treatment as a nonqualified withdrawal as discussed below. (See WITHDRAWALS Other Withdrawals. ) Qualified Withdrawals In general, a qualified withdrawal is any distribution from an Account that is used to pay for the Qualified Higher Education Expenses of a Beneficiary at an Eligible Educational Institution. Qualified Higher Education Expenses Qualified Higher Education Expenses currently include tuition, fees, and the cost of books, supplies, and equipment required for the enrollment or attendance of a Beneficiary at an Eligible Educational Institution (including expenses for special needs services in the case of a special needs Beneficiary that are incurred in connection with such enrollment or attendance), along with expenses for the purchase of computer or peripheral equipment (as defined in section 168(i)(2)(B) of the Code), computer software (as defined in section 197(e)(3)(B) of the Code), or Internet access and related services, if such equipment, software, or services are to be used primarily by the Beneficiary during any of the years the Beneficiary is enrolled at an Eligible Educational Institution. Computer software designed for sports, games, or hobbies is qualified only when the software is predominantly educational in nature. Also included as Qualified Higher Education Expenses are certain room and board expenses of a Beneficiary attending an Eligible Educational Institution at least half-time, as allowable under Section 529. Half-time is defined as half the fulltime academic workload for the course of study being pursued as determined under the standards of the Eligible Educational Institution where the Beneficiary is enrolled. A Beneficiary need not be enrolled at least half-time to use a qualified withdrawal to pay for expenses relating to tuition, fees, books, supplies, equipment, special needs services and computer and related equipment, software and services. Eligible Educational Institution Generally, Eligible Educational Institutions include accredited post-secondary educational institutions in the United States or abroad offering credit toward an associate s degree, a bachelor s degree, a graduate level or professional degree, or another recognized post-secondary credential, and certain post-secondary vocational and proprietary institutions. Such Eligible Educational Institutions must be eligible to participate in U.S. Department of Education student financial aid programs. For additional information, please visit Refunds If the Beneficiary receives from an Eligible Educational Institution a refund of funds originally withdrawn from an Account to pay for Qualified 18

23 Withdrawals Higher Education Expenses, such funds may be recontributed to an account in a 529 Plan for the same designated Beneficiary up to the amount of the refund provided that the re-contribution is made within 60 days of the date of the refund. Such funds also will not be subject to federal income tax or the additional 10% federal tax. For tax purposes, please maintain proper documentation evidencing the refund from the Eligible Educational Institution. Non-Qualified Withdrawals A non-qualified withdrawal is any withdrawal from an Account that is not a qualified withdrawal or listed below under Other Withdrawals. In accordance with Section 529, the earnings portion of a nonqualified withdrawal is treated as income to the distributee and is subject to federal and any applicable state income taxes as well as an additional 10% federal tax, except to the extent described below in the section entitled Other Withdrawals below. Although the Program Manager will report the earnings portion of all withdrawals, it is your final responsibility to calculate and report any tax liability and to substantiate any exemption from tax and/or penalty. Other Withdrawals Death of Beneficiary Upon the death of the Beneficiary, you may authorize a change in the Beneficiary who is a Member of the Family of the former Beneficiary for the Account, authorize a payment to the estate of the Beneficiary, or request the return of the Account balance. A distribution due to the death of the Beneficiary if paid to the estate of the Beneficiary will not be subject to the additional 10% federal tax on earnings, but earnings will be subject to federal and any applicable state income tax. A withdrawal of amounts in the Account, if not paid to the Beneficiary s estate, may constitute a nonqualified withdrawal subject to federal and applicable state income taxes at the distributee s tax rate and the additional 10% federal tax on earnings. If you select a new Beneficiary who is a Member of the Family of the former Beneficiary, you will not owe federal income tax or a penalty. Disability of Beneficiary If the Beneficiary becomes disabled, you may authorize a change in the Beneficiary who is a Member of the Family of the former Beneficiary for the Account or request the return of all or a portion of the Account balance. A withdrawal due to the qualified disability of the Beneficiary will not be subject to the additional 10% federal tax on earnings, but earnings will be subject to federal and any applicable state income tax at the Account Owner s tax rate. A person is considered to be disabled if he or she shows proof that he or she cannot do any substantial gainful activity because of his or her physical or mental condition. A physician must determine that his or her condition can be expected to result in death or to be of long-continued and indefinite duration. If you select a new Beneficiary who is a Member of the Family of the former Beneficiary, you will not owe federal income tax or a penalty. Receipt of Scholarship If the Beneficiary receives a qualified scholarship, Account assets up to the amount of the scholarship may be returned to you without imposition of the additional 10% federal tax on earnings. A qualified scholarship includes certain educational assistance allowances under federal law as well as certain payments for educational expenses (or attributable to attendance at certain educational institutions) that are exempt from federal income tax. The earnings portion of a distribution due to a qualified scholarship is subject to federal and any applicable state income tax at the distributee s tax rate. Rollover Distributions You may roll over all or part of the balance of an Account to an account in another 529 Plan not sponsored by the State of Nevada without adverse federal tax consequences under certain circumstances. (For more information concerning this type of rollover distribution, see CONTRIBUTIONS Rollover Contributions and Other Transfers. ) Currently, outgoing rollovers from the Plan can only be indirect. Transfers Among Other College Savings Plans Sponsored by the State of Nevada Transfers of account balances among the various college savings plans sponsored by the State of Nevada are treated as investment changes subject to the twice per calendar year limitation on the reallocation of prior contributions and not as tax-free 19

24 Withdrawals rollovers. If you reallocate your money within the Plan, that will count towards your twice per calendar year investment exchange limit. If you reach your twice per calendar year investment exchange limit, you may be prohibited under federal regulations from reallocating your investments in another 529 Plan sponsored by the State of Nevada during that year. (For more information concerning these types of transfers, see CONTRIBUTIONS Rollover Contributions and Other Transfers. ) Attendance at Certain Specified Military Academies If the Beneficiary attends the United States Military Academy, the United States Naval Academy, the United States Air Force Academy, the United States Coast Guard Academy, or the United States Merchant Marine Academy, you may withdraw an amount up to an amount equal to the costs of advanced education attributable to the Beneficiary s attendance at the institution without incurring the additional 10% federal tax on earnings. The earnings portion of the withdrawal will be subject to federal and any applicable state income tax at the distributee s tax rate. Use of Education Credits Taxpayers paying Qualified Higher Education Expenses from an Account will not be able to claim Education Credits for the same expenses. Furthermore, expenses used in determining the allowed Education Credits will reduce the amount of a Beneficiary s Qualified Higher Education Expenses to be paid from an Account as a qualified withdrawal and may result in taxable withdrawals. Such withdrawals, however, will not be subject to the additional 10% federal tax on earnings. Refunds from Eligible Educational Institutions If the Beneficiary receives from an Eligible Educational Institution a refund of funds originally withdrawn from an Account to pay for Qualified Higher Education Expenses, such funds up to the amount of the refund will not be subject to federal income tax or the additional 10% federal tax; provided that the funds are recontributed to an account in a 529 Plan for the same Beneficiary, to the extent such recontribution is made not later than 60 days after the date of the refund and does not exceed the refund amount. For tax purposes, please maintain proper documentation evidencing the refund from the Eligible Educational Institution. Records Retention Under current federal tax law, you are responsible for obtaining and retaining records, invoices, or other documentation adequate to substantiate, among other things, the following: (i) expenses that you claim are Qualified Higher Education Expenses, (ii) the death or qualified disability of the Beneficiary, (iii) the receipt by the Beneficiary of a qualified scholarship, (iv) the attendance by the Beneficiary at certain specified military academies, (v) the use of Education Credits, or (vi) a refund from an Eligible Institution that is re-contributed to a 529 Plan within 60 days of the date of the refund. Residual Account Balances If the Beneficiary graduates from an Eligible Educational Institution or chooses not to pursue higher education and funds remain in the Account, you can choose from three options. A. First, if you request, the remaining funds (including earnings) will be returned to you and treated as a non-qualified withdrawal. Earnings will be subject to federal and any applicable state income tax, including the additional 10% federal tax on earnings. B. Second, you may authorize a change of Beneficiary for the Account to a Member of the Family of the current Beneficiary. C. Third, you may keep the funds in the Account to pay future Qualified Higher Education Expenses (such as graduate or professional school expenses) of the current Beneficiary. Option C above would not be a withdrawal, and option B above would not constitute a non-qualified withdrawal. There is no specific deadline for the use of assets in an Account to pay for Qualified Higher Education Expenses. However, the Board may establish a maximum duration for the Account. 20

25 Federal and State Tax Treatment FEDERAL AND STATE TAX TREATMENT This section summarizes key aspects of the U.S. federal and state tax treatment of contributions to, and withdrawals from, 529 Plan accounts. The information provided below is not exhaustive. It is based on the Plan s understanding of current law and regulatory interpretations relating to 529 Plans generally and is meant to provide 529 Plan participants with general background about the tax characteristics of these programs. Neither this Federal and State Tax Treatment section, nor any other information provided throughout this Plan Description is intended to constitute, nor does it constitute, legal or tax advice. This Plan Description was developed to support the marketing of the Wealthfront 529 College Savings Plan and cannot be relied upon for purposes of avoiding the payment of federal or state tax penalties. You should consult your legal or tax advisor about the impact of federal and state tax rules and regulations on your individual situation. The summary tax and legal description provided below is based on the Code and proposed regulations in effect as of the date of this Plan Description, as well as other administrative guidance and announcements issued by the IRS and the U.S. Department of Treasury. It is possible that Congress, the Treasury Department, the IRS, or federal or state courts may take action that will affect the tax treatment of 529 Plan contributions, earnings, or withdrawals or the availability of state tax deductions. Individual state legislation may also affect the state tax treatment of a 529 Plan for residents of that state. The Plan strongly encourages you and your Beneficiaries to consult with your tax advisors regarding the tax consequences of contributing money to, or withdrawing money from, an Account. If you are not a Nevada taxpayer, consider before investing whether your or the Beneficiary s home state offers a 529 Plan that provides its taxpayers with favorable state tax and other benefits that may only be available through investment in the home state s 529 Plan and that are not available through investment in the Plan. Because different states have different tax provisions, this Plan Description contains limited information about the state tax consequences of investing in the Plan. Therefore, please consult your financial, tax, or other advisor to learn more about how state-based benefits (or any limitations) would apply to your specific circumstances. You also may wish to contact your home state s 529 Plan(s), or any other 529 Plan, to learn more about those plans features, benefits and limitations. Keep in mind that state-based benefits should be one of many appropriately weighted factors to be considered when making an investment decision. 529 Plans Generally Among the most notable tax advantages of 529 Plans is that the earnings portion of a qualified withdrawal is exempt from federal taxes. To be eligible for these tax benefits, 529 Plan account assets must be used to pay the Qualified Higher Education Expenses of the Beneficiary at an Eligible Educational Institution. Important Tax Consideration The U.S. Treasury Department has issued proposed regulations under Section 529. The Plan is designed to comply with the proposed regulations (except to the extent that provisions in the proposed regulations have been superseded by legislative and/or administrative changes), as well as with certain other guidance issued by the IRS under Section 529. However, there is no assurance that the proposed regulations will become the final regulations or that the IRS will not issue other guidance interpreting Section 529. In any event, you should consult with a qualified tax advisor as to the effect any change in the law could have on your Account. 529 Plan Contributions and Withdrawals Federal law does not allow a tax deduction for contributions to 529 Plans. Certain tax considerations apply to the method of contribution to an Account. (See CONTRIBUTIONS Rollover Contributions and Other Transfers. ) The income earned on any such contributions may generally grow federal income tax free until distributed. Qualified withdrawals (i.e., withdrawals to pay for the Qualified Higher Education Expenses of a Beneficiary at an Eligible Educational Institution) and qualified rollovers are not subject to federal income taxation. The earnings portion of nonqualified withdrawals, however, is subject to all applicable federal and state income taxes and, in most cases, an additional 10% federal tax on earnings. As described in WITHDRAWALS Other Withdrawals, there are several exceptions to the additional 10% federal tax on earnings required under Section 529 of the Code: (1) withdrawals made from the Account in the event of the Beneficiary s death (if paid to the beneficiary of the Beneficiary or the Beneficiary s estate), (2) withdrawals made from the Account in the event of the Beneficiary s disability, 21

26 Federal and State Tax Treatment (3) receipt of a qualified scholarship, allowance, or similar payment made to the Beneficiary as described in Section 529(c)(6) of the Code, but only to the extent of such qualified scholarship, allowance, or payment, (4) withdrawals on Account of the Beneficiary s attendance at certain specified military academies, (5) amounts not treated as qualified withdrawals due to the use of Education Credits, (6) qualified rollovers, and (7) a refund from an Eligible Educational Institution that is re-contributed to a 529 Plan within 60 days of the date of the refund. The earnings portion of a withdrawal will generally be calculated on an Account-by-Account basis. An Account Owner may only open one Account in the Plan for the same Beneficiary. Withdrawals from an Account will be taken proportionally from all of the Designated Portfolios in an Account. Qualified Rollovers An Account Owner may transfer all or part of the funds in a 529 Plan account to an account in another 529 Plan without adverse federal income tax consequences if, within 60 days of the withdrawal from the distributing account, such funds are transferred to or deposited into an account at another 529 Plan for the benefit of (1) an individual who is a Member of the Family of the original Beneficiary; or (2) the same Beneficiary, but only if no other such rollover distribution or transfer has been made for the benefit of such individual within the preceding 12 months. Transfers between 529 Plans sponsored by the State of Nevada are not subject to this rule. (See CONTRIBUTIONS Transfer into a Plan Account from Another Plan within the Trust for the Benefit of the Same Beneficiary. ) Other Contributions and Transfers An individual may generally transfer into a 529 Plan account, without adverse federal income tax consequences, all or part of money held in an Account for a Member of the Family of the Beneficiary if the money is transferred within 60 days of the withdrawal from the distributing account. Coordination with Other Higher Education Expense Benefit Programs The federal tax benefits afforded to 529 Plans must be coordinated with other programs designed to provide tax benefits for meeting higher education expenses in order to avoid the duplication of such benefits. The coordinated programs include the Education Credits under Section 25A of the Code. Education Credits The use of Education Credits by a qualifying Account Owner and Beneficiary will not affect participation in or receipt of benefits from a 529 Plan account so long as any withdrawal from the 529 Plan account is not used for the same expenses for which the credit was claimed. Federal Gift and Estate Taxes Contributions (including certain rollover contributions) to a 529 Plan account generally are considered completed gifts to the Beneficiary and are eligible for the applicable annual exclusion from gift and generation-skipping transfer taxes (in 2016, $14,000 for a single individual or $28,000 for a married couple electing to split gifts). Except in the situations described in the following paragraph, if the contributor were to die while assets remain in a 529 Plan account, the value of the account would not be included in the contributor s estate. In cases where annual contributions to a 529 Plan account by a contributor exceed the applicable annual exclusion amount, the contributions are subject to federal gift tax and possibly the generation-skipping transfer tax in the year of contribution. However, in these cases, the contributor may elect to apply the contribution against the annual exclusion equally over a five-year period. This option is applicable only for contributions up to five times the available annual exclusion amount in the year of the contribution. For example, for 2016, the maximum contribution that may be made using this rule would be $70,000 (or $140,000 for a married couple electing to split gifts). Once this election is made, if the contributor makes any additional gifts to the same Beneficiary in the same or the next four years, such gifts are subject to gift or generation-skipping transfer taxes in the calendar year of the gift. However, any excess gifts may be applied against the contributor s lifetime gift tax exemption. If the contributor chooses to use the five-year forward election and dies before the end of the fiveyear period, the portion of the contribution allocable to the years remaining in the five-year period (beginning with the year after the contributor s death) would be included in the contributor s estate for federal estate tax purposes. If the beneficiary of a 529 Plan account is changed or amounts in an account are rolled over to a new beneficiary of the same generation as the former beneficiary and the new beneficiary is a Member of the Family of the former beneficiary, there are no gift or generation-skipping transfer tax consequences. If the new beneficiary is of a younger generation than 22

27 Federal and State Tax Treatment the former beneficiary or is not a Member of the Family of the former beneficiary, the former beneficiary will have made a taxable gift to the extent of the amount transferred. If the new beneficiary is two or more generations below the former beneficiary, the change or rollover will be subject to generation-skipping transfer tax. The five-year rule explained above may be applied here. The gross estate of a beneficiary may include the value of the 529 Plan account. Estate, gift, and generation-skipping tax issues arising in conjunction with 529 Plans can be quite complicated. You should consult with your tax advisor if you have any questions about these issues. State Taxes You should consider many factors before deciding to invest in a 529 Plan such as the Plan, including the plan s investment options and its performance history, the plan s flexibility and features, the reputation and expertise of the plan s investment manager(s), the plan s contribution limits, the plan s fees and expenses, and federal and state tax benefits associated with an investment in the plan. The State of Nevada does not impose an income tax on individuals. Thus, there are no State of Nevada income tax consequences to either contributors to, or recipients of money withdrawn from, the Plan. It is possible, however, that a contributor to the Plan may be entitled to a deduction in computing the income tax imposed by a state where he or she lives or pays taxes. Likewise, it is possible that a recipient of money withdrawn from the Plan may be subject to income tax on those withdrawals by the state where he or she lives or pays taxes. It is also possible that amounts rolled over into the Plan from another state s 529 Plan may be subject to a state tax imposed on the rollover amount. You should consult with your tax advisor regarding the state tax consequences of participating in the Plan. 23

28 Investments INVESTMENTS Wealthfront serves as your automated investment adviser. Under the Plan, Wealthfront constructs an Individual Portfolio for you using Designated Portfolio Units from up to nine Designated Portfolios, each of which contains a single underlying ETF. The underlying ETF contained within each of the Designated Portfolios is an exchange-traded investment product registered with the SEC under the Investment Company Act of Like mutual funds, ETFs offer investors a way to pool their money in a fund that makes investments in stocks, bonds, or other assets and, in return, to receive an interest in that investment pool. Unlike mutual funds, however, ETF shares are traded on a national stock exchange and at market prices that may or may not be the same as the net asset value of the shares (the value of the ETF s assets minus its liabilities divided by the number of shares outstanding). Each Designated Portfolio invests in the shares of a single ETF chosen by Wealthfront to best represent a particular asset class. (For a listing of the Designated Portfolios and their underlying ETFs, see FEES AND EXPENSES below.) Wealthfront designs your Individual Portfolio to provide you a diversified asset allocation based on your individual risk tolerance as reflected by your Risk Score, which is determined by your responses to a Risk Questionnaire. Using your Risk Score, Wealthfront assigns your Individual Portfolio to one out of 20 Glide Paths, each of which determines how your Individual Portfolio s allocations of Designated Portfolios will change over time. Each Glide Path gradually shifts the asset allocations of the Designated Portfolios in your Individual Portfolio to progressively decreasing levels of expected risk as the Expected Matriculation Date approaches. Your starting point along the specific Glide Path is determined by the Beneficiary s Expected Matriculation Date. Thus, two Account Owners with identical Risk Scores and Beneficiaries of different ages will transition along the same Glide Path, but will start at different points on the Glide Path due to the different investment time horizons. Wealthfront implements Glide Paths by identifying: (1) the optimal asset classes in which to invest; (2) the most efficient ETFs or other investments to represent each of those asset classes; (3) the optimized mix of asset classes based on the Account Owner s specific risk tolerance and the time until the Expected Matriculation Date; and (4) the most appropriate time to rebalance the Account Owner s Individual Portfolio. For more information concerning Wealthfront s asset allocation and Glide Path construction methodologies, please see APPENDIX A Investments. Unlike many other 529 Plans, your assets are not managed in a commingled fund structure. In a commingled fund structure, you buy a single fund. In this Plan, each Individual Portfolio is managed separately, and will be allocated to up to nine Designated Portfolios as prescribed by your Risk Score and your Beneficiary s Expected Matriculation Date. The Glide Path assigned to an Individual Portfolios upon Account opening will serve as your standing investment allocation for the Account. All of your additional contributions will be invested according to this standing allocation. Federal tax law permits you to move existing Account assets to a different mix of investment options only up to two times per calendar year or whenever the Account Owner changes the Beneficiary. When you change your Risk Score, you will change your existing Account assets to a different mix of investments. Thus, under federal tax law, you can change your Risk Score only up to two times per calendar year and upon a change in the Beneficiary. Automatic investment exchanges that occur as your Individual Portfolio moves on a Glide Path do not count towards the twice per calendar year investment exchange limit. (See FEDERAL AND STATE TAX TREATMENT for treatment of transfers between an Account in the Plan and another plan sponsored by the State of Nevada.) Additional Designated Portfolios may be available in the future. Account Owners should be aware that any Designated Portfolios might merge, terminate, reorganize, or cease accepting new contributions. Any such action affecting a Designated Portfolio may result in your contributions being reinvested in a Designated Portfolio different from the Designated Portfolio in which contributions were originally invested. The Board may at any time, without prior notice, change the Designated Portfolios, and Wealthfront may at any time, without prior notice, change the Glide Paths as described in APPENDIX A Investments Glide Path Construction. In accordance with applicable agreements, the Board reserves the right to change the Program Manager. There can be no assurance that Wealthfront s investment strategy will be successful. Please keep in mind that you will not own shares of the underlying ETFs. You are purchasing Designated 24

29 Investments Portfolio Units in the Trust, which invests your money in the underlying ETF. Contributions to the Designated Portfolios are invested in accordance with the investment policy established by the Board. The Board may change the investment policy for the Designated Portfolios at any time. As required by the Act and Section 529, you are only permitted to change the existing investments in your Account(s) for a particular Beneficiary by changing your Risk Score up to two times per calendar year or upon a change of the Beneficiary. If you reach your twice per calendar year change limit, you will be prohibited under federal regulations from reallocating your investments in another 529 Plan sponsored by the State of Nevada during that year. For more detailed information about the Plan s investments, please see APPENDIX A. 25

30 Fees and Expenses FEES AND EXPENSES The Board, in its sole discretion, will establish Plan fees and expenses as it deems appropriate and may change, or add new, fees and expenses at any time without prior notice. In the future, Plan expenses and fees could be higher or lower than those discussed below. Expenses and fees reduce the value of an Account. Wealthfront Advisory Fee If you open an Account, you are an investment advisory client of Wealthfront. Wealthfront is compensated for its advisory services by charging you an advisory fee based on the net market value of an Account ( Wealthfront Advisory Fee ). Wealthfront reserves the right to reduce or waive the Wealthfront Advisory Fee for certain Accounts for any period of time as determined by Wealthfront. In addition, Wealthfront may reduce or waive its Wealthfront Advisory Fee for the Accounts of some Account Owners without notice and without reducing or waiving its Wealthfront Advisory Fees for other Plan Account Owners pursuant to Wealthfront s policies and marketing programs and promotions as set forth on Wealthfront s website at as may be amended from time to time. Wealthfront charges you an annualized Wealthfront Advisory Fee of 0.25% of the assets under management in each of your Accounts in the Plan. Wealthfront does not charge the Wealthfront Advisory Fee in advance. The fee is calculated on a continuous basis and is deducted from your Account each month as follows: Wealthfront calculates your daily Wealthfront Advisory Fee, which is equal to the annual fee rate multiplied by the net market value of your Account as of the close of trading on the NYSE on such day, or as of the close of markets on the immediately preceding trading day for any day when the NYSE is closed, and then divided by 365 (or 366 in any leap year). Your Wealthfront Advisory Fee for a calendar month is equal to the total of your daily Wealthfront Advisory Fees calculated during that month (less any reductions or fee waivers, e.g., for the fee waiver on the first $10,000 of assets in all accounts under management by Wealthfront) and is deducted from your Account no later than the tenth business day of the following month through Wealthfront s redemption of the appropriate amount of Designated Portfolio Units. In addition, for Nevada residents who open an Account, Wealthfront waives investment advisory fees, including the Wealthfront Advisory Fee, for an additional $15,000 of assets ($25,000 of assets in total) in your Wealthfront account(s) in and outside of the Plan in the aggregate. Thus, by opening an Account, a Nevada resident will increase the waiver of his or her Wealthfront investment advisory fees from the first $10,000 of assets under management with Wealthfront to the first $25,000 of assets under management. Wealthfront s fee waivers are applied proportionately across all Wealthfront advisory accounts based on the assets in each such account and the total assets in all such accounts. Annual Asset-Based and Total Fees for Designated Portfolios Each Designated Portfolio also is subject to the following annual Asset-Based Fees, each of which is defined in the following sections below: Underlying ETF Fee; Ascensus Program Management Fee; and Board Fee. The above fees are deducted from Designated Portfolio assets, which means you will pay them indirectly. Each Individual Portfolio will indirectly bear its pro rata share of the Annual Asset-Based Fee of the Designated Portfolios within it. These fees and expenses reduce the return the Account Owner will receive from an investment in the Plan. The Annual Asset-Based Plan Fee of a Designated Portfolio may fluctuate as a result of fluctuations in the Underlying ETF Fee. The Board may change or add new fees at any time, without prior notice. Underlying ETF Fee Each Individual Portfolio invested in a Designated Portfolio will indirectly bear its pro-rata share of certain expenses of the ETF ( Underlying ETF Fee ) underlying that Designated Portfolio. The Underlying ETF Fee, which is paid to the investment managers/sponsors of the underlying ETF in each of the Designated Portfolios, includes the annual operating expenses associated with each Designated Portfolio s underlying investments. The Underlying ETF Fee is subject to fluctuation from time to time based on changes in these annual operating expenses. Ascensus Program Management Fee For providing administration and program management services for the Plan, the Program 26

31 Fees and Expenses Manager receives an annual fee equal to 0.05% of assets in each Designated Portfolio ( Ascensus Program Management Fee ) pursuant to the terms of the Operating Agreement. Board Fee The Board collects a fee based on the assets in each Designated Portfolio ( Board Fee ) to pay for expenses related to oversight and administration of the Trust. If assets in the Plan are $5 billion or less, each Designated Portfolio will bear an annualized fee of 0.01% based on the assets in such Designated Portfolio that is used to pay the Board Fee. However, if assets in the Plan are less than $1 billion, the Board Fee will be an annual fixed fee equal to $100,000, and Wealthfront (not you as the Account Owner through your investment in a Designated Portfolio) will directly pay the portion of the Board Fee equal to the difference between the 0.01% annualized fee for all Designated Portfolios and the annual fixed fee of $100,000. If assets in the Plan are greater than $5 billion, the annualized fee borne by each Designated Portfolio will be reduced below 0.01% based on the assets in such Designated Portfolio such that the entire amount of the fees for all Designated Portfolios equals a fixed annual fee of $500,000, which is paid to the Board as the Board Fee. 27

32 Fees and Expenses The following table summarizes the annual Asset-Based and Total Fees for each Designated Portfolio. Designated Portfolio Short Treasury Bond Portfolio Corporate Bond Portfolio Short-Term Inflation Protected Securities Portfolio Emerging Markets Bond Portfolio REIT Portfolio Dividend Stock Portfolio Total Stock Market Portfolio International Stock Portfolio Emerging Markets Stock Portfolio ANNUAL ASSET-BASED AND TOTAL FEES FOR EACH DESIGNATED PORTFOLIO AS OF JUNE 30, 2016 Underlying Asset Class Asset-Based Designated Portfolio Fees Asset-Based ETF (Ticker Account Fee Symbol) ishares Short Treasury Bond ETF (SHV) ishares iboxx $ Investment Grade Corp Bond ETF (LQD) Vanguard Short--Term Inflation- Protected Securities ETF (VTIP) ishares JPMorgan USD Emerging Markets Bond ETF (EMB) Vanguard REIT ETF (VNQ) Vanguard Dividend Appreciation ETF (VIG) Vanguard Total Stock Market ETF (VTI) Vanguard FTSE Developed Markets ETF (VEA) Vanguard FTSE Emerging Markets ETF (VWO) US Treasury Bills US Investment Grade Corporate Bonds Underlying ETF Fee 1 Ascensus Program Management Fee Board Fee 2 Total Asset- Based Designated Portfolio Fee 3 Wealthfront Advisory Fee 4 Total Fee 5 T-Bills - Designated Portfolio 0.15% 0.05% 0.01% 0.21% 0.25% 0.46% Bonds - Designated Portfolios 0.15% 0.05% 0.01% 0.21% 0.25% 0.46% US TIPS 0.08% 0.05% 0.01% 0.14% 0.25% 0.39% Emerging Markets Bonds US REITs 0.40% 0.05% 0.01% 0.46% 0.25% 0.71% Stocks - Designated Portfolios 0.12% 0.05% 0.01% 0.18% 0.25% 0.43% US Dividend Growth Stocks 0.09% 0.05% 0.01% 0.15% 0.25% 0.40% US Stocks 0.05% 0.05% 0.01% 0.11% 0.25% 0.36% International Developed Stocks Emerging Markets Stocks 0.09% 0.05% 0.01% 0.15% 0.25% 0.40% 0.15% 0.05% 0.01% 0.21% 0.25% 0.46% 28

33 Fees and Expenses Source: underlying ETF prospectuses. If assets in the Plan are $5 billion or less, each Designated Portfolio will bear an annualized fee of 0.01% based on the assets in such Designated Portfolio that is used to pay the Board Fee. However, if assets in the Plan are less than $1 billion, the Board Fee will be an annual fixed fee equal to $100,000, and Wealthfront (not you as the Account Owner through your investment in a Designated Portfolio) will directly pay the portion of the Board Fee equal to the difference between the 0.01% annualized fee for all Designated Portfolios and the annual fixed fee of $100,000. If assets in the Plan are greater than $5 billion, the annualized fee borne by each Designated Portfolio will be reduced below 0.01% based on the assets in such Designated Portfolio such that the entire amount of the fees for all Designated Portfolios equals a fixed annual fee of $500,000, which is paid to the Board as the Board Fee. Includes the Underlying ETF Fee, Program Management Fee and Board Fee. This total is assessed against assets in the Designated Portfolios over the course of the year. Currently, Wealthfront waives its investment advisory fees for the first $10,000 of assets in any Wealthfront investment advisory account(s) including Accounts in the Plan. In addition, for Nevada residents who open an Account, Wealthfront waives investment advisory fees for an additional $15,000 of assets ($25,000 of assets in total) in his or her Wealthfront account(s) in and outside of the Plan in the aggregate. Thus, by opening an Account, a Nevada resident will increase the waiver of your Wealthfront investment advisory fees from the first $10,000 of assets under management with Wealthfront to the first $25,000 of assets under management. This equals the sum of the total Asset-Based Fee for each Designated Portfolio plus the Wealthfront Advisory Fee charged to each Account, as described in the preceding footnote 4. Please note that this does not reflect the actual cost to the Account Owner based on the Account Owner s specific Individual Portfolio. Each Individual Portfolio will bear its total Asset-Based Fees based on the asset allocation of the Designated Portfolios within such Individual Portfolio. See Individual Portfolio Fees by Glide Path immediately below. 29

34 Fees and Expenses Individual Portfolio Fees by Glide Path The following table is intended to provide you with an understanding of the magnitude of the ranges of total fees that you might expect from your Individual Portfolio, which is a combination of Designated Portfolios and that is assigned to one of 20 Glide Paths. INDIVIDUAL PORTFOLIO FEES BY GLIDE PATH AS OF JUNE 30, 2016 Glide Path Asset- Based Designated Portfolio Fees Asset-Based Account Fee Total Fee Range Combined Underlying ETF Fee Range 1 Ascensus Program Management Fee Board Fee 2 Total Asset-Based Fee Range Wealthfront Advisory Fee 3 Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.18% % 0.25% 0.43% % Glide Path % % 0.05% 0.01% 0.19% % 0.25% 0.44% % Glide Path % % 0.05% 0.01% 0.19% % 0.25% 0.44% % Glide Path % % 0.05% 0.01% 0.19% % 0.25% 0.44% % Glide Path % % 0.05% 0.01% 0.20% % 0.25% 0.45% % Glide Path % % 0.05% 0.01% 0.21% % 0.25% 0.46% % Glide Path % % 0.05% 0.01% 0.20% % 0.25% 0.45% % Glide Path % % 0.05% 0.01% 0.21% % 0.25% 0.46% % 1 For a given Glide Path, the Combined Underlying ETF Fee Range reflects the maximum and minimum ETF fees that you would be subject to a given time during the 18-year life of the selected Glide Path currently in place assuming that your Risk Score and the Underlying ETF Fees do not change. The Combined Underlying ETF Fee varies as your Individual Portfolio transitions across the allocations along the Glide Path. Please note that if your Risk Score changes, you may move to a different Glide Path and incur a different range of maximum and minimum Underlying ETF Fees as reflected in this table. Please note further that in the future, Glide Paths may vary from those currently in place due to changes in the markets, the relationships between the returns and volatilities between various asset classes, opportunities to optimize Glide Path construction, and changes in the Designated Portfolios and their underlying ETFs. 2 If assets in the Plan are $5 billion or less, each Designated Portfolio will bear an annualized fee of 0.01% based on the assets in such Designated Portfolio that is used to pay the Board Fee. However, if assets in the Plan are less than $1 billion, the Board Fee will be an annual fixed fee equal to $100,000, and Wealthfront (not you as the Account Owner through your investment in a Designated Portfolio) will directly pay the portion of the Board Fee equal to the difference between the 0.01% annualized fee for all Designated Portfolios and the annual fixed fee of $100,000. If assets in the Plan are greater than $5 billion, the annualized fee borne by each Designated Portfolio will be reduced below 0.01% based on the assets in such Designated Portfolio such that the entire amount of the fees for all Designated Portfolios equals a fixed annual fee of $500,000, which is paid to the Board as the Board Fee. 3 Currently, Wealthfront waives its investment advisory fees for the first $10,000 of assets in any Wealthfront investment advisory account(s) including Accounts in the Plan. In addition, for Nevada residents who open an 30

35 Fees and Expenses Account, Wealthfront waives investment advisory fees for an additional $15,000 of assets ($25,000 of assets in total) in his or her Wealthfront account(s) in and outside of the Plan in the aggregate. Thus, by opening an Account, a Nevada resident will increase the waiver of his or her Wealthfront investment advisory fees from the first $10,000 of assets under management with Wealthfront to the first $25,000 of assets under management. Example of Maximum Investment Costs of Individual Portfolios by Glide Path The following table describes the approximate maximum costs of investing in an Individual Portfolio by Glide Path over different periods of time. They illustrate the hypothetical maximum expenses that you would incur over various periods if you invest $10,000 in an Individual Portfolio made up of Designated Portfolios selected and allocated by Wealthfront in accordance with the respective Glide Path. An Account Owner s actual cost may be higher or lower based on assumptions that are different from the following assumptions: Glide Path A $10,000 principal investment for the time periods shown; A 5% annually compounded rate of return on the principal amount invested throughout the period; All Trust Interests are redeemed at the end of the period shown for Qualified Higher Educational Expenses (the examples do not consider the impact of any potential state or federal taxes on the redemption); The maximum of the annual Asset-Based Fee and Total Fee remains the same as shown in the table on page 30; Account Owner will be paying the full Wealthfront Advisory Fee of 0.25% and that the Account is not subject to any Wealthfront Advisory Fees waivers or reductions. Maximum Account Owner Expense Reflecting Only Asset-Based Fees Maximum Account Owner Expense Reflecting Asset-Based Fees and Wealthfront Advisory Fee 1 Year 3 Year 5 Year 10 Year 1 Year 3 Year 5 Year 10 Year Glide Path 100 $22 $63 $108 $237 $47 $144 $248 $553 Glide Path 95 $22 $64 $107 $234 $47 $144 $247 $549 Glide Path 90 $22 $64 $108 $236 $47 $145 $248 $552 Glide Path 85 $22 $67 $113 $243 $47 $147 $254 $558 Glide Path 80 $22 $67 $116 $249 $47 $148 $256 $564 Glide Path 75 $22 $68 $117 $252 $48 $148 $257 $567 Glide Path 70 $22 $68 $117 $254 $48 $148 $258 $570 Glide Path 65 $22 $68 $118 $257 $48 $148 $258 $573 Glide Path 60 $22 $68 $118 $259 $48 $148 $258 $574 Glide Path 55 $22 $68 $118 $260 $48 $148 $258 $575 Glide Path 50 $22 $68 $118 $261 $48 $149 $258 $576 Glide Path 45 $22 $68 $118 $262 $48 $149 $258 $577 Glide Path 40 $22 $68 $118 $263 $48 $149 $259 $579 Glide Path 35 $22 $69 $119 $265 $48 $149 $259 $580 Glide Path 30 $22 $69 $119 $265 $48 $149 $259 $580 Glide Path 25 $22 $69 $119 $265 $48 $149 $260 $580 Glide Path 20 $22 $69 $120 $266 $48 $149 $260 $581 Glide Path 15 $22 $69 $120 $267 $48 $149 $260 $582 Glide Path 10 $22 $69 $119 $266 $48 $149 $260 $581 Glide Path 5 $22 $69 $120 $267 $48 $149 $260 $582 31

36 Fees and Expenses Certain Transaction Fees The Plan also will impose certain transaction fees for the transactions specified below: Transaction Rejected Recurring Contribution Fee Amount* $30 Rejected EFT $30 Priority Delivery** $15 weekday *Subject to change without prior notice. All fees listed may be considered non-qualified withdrawals. You should consult your tax advisor regarding calculating and reporting any tax liability as applicable. ** The Plan will report the fees (and other optional convenience fees as applicable) as distributions on Form Q. 32

37 Plan Risks PLAN RISKS AND DESIGNATED AND INDIVIDUAL PORTFOLIO RISKS You should carefully consider the information in this section as well as the other information in this Plan Description before making any decisions to establish an Account or make any contributions. The contents of this Plan Description should not be construed as legal, financial, or tax advice. You should consult an attorney or a qualified financial or tax advisor with any legal, business, or tax questions you may have. The Plan is an investment vehicle, and by opening an Account, you are establishing an investment advisory relationship with Wealthfront. Wealthfront cannot guarantee any level of performance or that you will avoid a loss of Account assets. Any investment in securities involves the possibility of financial loss that you should be prepared to bear. Accounts in the Plan are subject to certain risks. Certain Designated Portfolios carry more and/or different risks than others, and Individual Portfolios are subject to varying levels of risks (more or less based on which Glide Path the Individual Portfolios track and where on the Glide Path it is) based on its constituent Designated Portfolios. You should weigh such risks with the understanding that these risks could arise at any time during the life of an Account. Wealthfront Advisory Risk There is no guarantee that Wealthfront s judgment or investment decisions about particular securities, asset classes, Glide Paths, or Individual Portfolios will necessarily produce the intended results. Wealthfront s judgment may prove to be incorrect, and you might not achieve the desired investment objectives. Wealthfront also may make future changes to the investing algorithms and advisory services that it provides. In addition, it is possible that you or Wealthfront itself may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to Wealthfront s software-based automated investment service. Wealthfront and its representatives are not responsible to you for losses unless caused by Wealthfront breaching its fiduciary duty to you as an investment adviser. Risks of Investing in the Plan Investing in the Plan involves certain risks, including the possibility that you may lose money over short or even long periods of time. In addition to the investment risks of the Designated Portfolios, described in APPENDIX A, there are certain risks relating to the Plan generally, as described more fully below. No Guarantee of Principal or Earnings; No Insurance The value of your Account may increase or decrease over time based on the performance the Designated Portfolios that constitute your Individual Portfolio. It is possible that, at any given time, your Account value may be less than the total amount contributed. None of the Plan Officials is an insurer of, makes any guarantee of, or has any legal obligations to ensure, a particular level of investment return. You should be aware that you could lose all or a portion of your investment, depending on market conditions. An investment in the Plan is not a bank deposit. The Plan is not insured or guaranteed. None of your Account, the principal you invest, nor any investment return is insured or guaranteed by the Plan Officials, the federal government, the FDIC, or any other governmental agency. Relative to investing for retirement, the holding period for college investors is very short (e.g., 5-20 years versus years). Also, the need for liquidity during the withdrawal phase (to pay for Qualified Higher Education Expenses) generally is very important. You should strongly consider the level of risk you wish to assume when completing the Risk Questionnaire upon Account opening. Limited Investment Direction You may not direct the underlying investments in an Account. The ongoing money management is the responsibility of Wealthfront. The only manner in which you can affect the money management is to change your Risk Score, which is limited to two times per year, or upon the change of the Beneficiary. Once the permitted two per calendar year Risk Score changes are made in our Account, a subsequent Risk Score change in your Account within the same calendar year will not be processed. The choice of the underlying investments of the Designated Portfolios is subject to the approval of the Board. Automatic investment exchanges that occur as your assets move through the Glide Path do not count towards your twice per calendar year investment exchange limit. Liquidity Investments in a Section 529 Plan are considered less liquid than other types of investments (e.g., investments in mutual fund shares) because the circumstances in which an Account owner may withdraw money from a Section 529 Plan account without a penalty or adverse tax consequences are significantly more limited. 33

38 Plan Risks Potential Changes to the Plan The Board reserves the right, in its sole discretion, to discontinue the Plan or to change any aspect of the Plan. For example, the Board may change the Plan s fees and expenses; add, subtract, or merge the Designated Portfolios; close a Designated Portfolio to new investors; or change the Program Manager or the underlying investment(s) of a Designated Portfolio. Depending on the nature of the change, you may be required to, or prohibited from, participating in the change with respect to Accounts established before the change. ABD may not necessarily continue as Program Manager, and Wealthfront may not necessarily continue as investment adviser and distributor to the Plan (although Wealthfront will continue as your investment adviser until either Wealthfront or you terminate that investment advisory relationship). If you have established Accounts prior to the time such changes are made to the Plan, you may be required to participate in such changes or may be prohibited (according to Section 529 regulations or other guidance issued by the IRS) from participating in such changes, unless you open a new Account. Furthermore, the Board may terminate the Plan by giving written notice to you, but the Plan may not thereby be diverted from the exclusive benefit of you and the Beneficiary. During the transition from one underlying investment to another underlying investment, a Designated Portfolio may be temporarily uninvested and lack market exposure to an asset class. The transaction costs associated with any liquidation, as well as any market impact on the value of the securities being liquidated, will be borne by the Designated Portfolio and Individual Portfolios holding that Designated Portfolio. Status of Federal and State Law and Regulations Governing the Plan Federal and state law and regulations governing the administration of Section 529 Plans could change in the future. In addition, federal and state laws on related matters, such as the funding of higher education expenses, treatment of financial aid, and tax matters are subject to frequent change. It is unknown what effect these kinds of changes could have on an account. You should also consider the potential impact of any other state laws on your Account. You should consult your tax advisor for more information. No Indemnification Neither the Plan Officials, nor any other person will indemnify you or your Beneficiary against losses or other claims arising from the official or unofficial acts, negligent or otherwise, of Board members or State employees. Eligibility for Financial Aid The treatment of Account assets may have an adverse effect on your Beneficiary s eligibility to receive assistance under various federal, state, and institutional financial aid programs. In making decisions about eligibility for financial aid programs offered by the U.S. government and the amount of such aid required, the U.S. Department of Education takes into consideration a variety of factors, including among other things the assets owned by the student (i.e., the Beneficiary) and the assets owned by the student s parents. The U.S. Department of Education generally expects the student to spend a substantially larger portion of his or her own assets on educational expenses than the parents. For federal financial aid purposes, Account assets will be considered (i) assets of a student s parent, if the student is a dependent student and the owner of the Account is the parent or the student, or (ii) assets of the student, if the student is the owner of the Account and not a dependent student. For purposes of financial aid programs offered by states, other non-federal sources, and educational institutions, the treatment of Account assets may follow or differ from the treatment described above for federal financial aid purposes. Account Owners and Beneficiaries are advised to consult a financial aid professional and/or the state or educational institution offering a particular financial aid program, to determine how assets held in an Account may affect eligibility for financial aid. Under Nevada law, assets in an Account are not taken into consideration in determining the eligibility of the Beneficiary, parent or guardian of the Account for a grant, scholarship or work opportunity that is based on need and offered or administered by a state agency, except as otherwise required by the source of the funding of the grant, scholarship or work opportunity. 34

39 Plan Risks The federal and non-federal financial aid program treatments of assets in a 529 Plan are subject to change at any time. You therefore should check and periodically monitor the applicable laws and other official guidance, as well as particular program and institutional rules and requirements, to determine the impact of 529 Plan assets on eligibility under particular financial aid programs. No Guarantee That Investments Will Cover Qualified Higher Education Expenses; Inflation and Qualified Higher Education Expenses There is no guarantee that the money in your Account will be sufficient to cover all of a Beneficiary s Qualified Higher Education Expenses, even if contributions are made in the maximum allowable amount for the Beneficiary. The future rate of increase in Qualified Higher Education Expenses is uncertain and could exceed the rate of investment return earned by an Account over any relevant period of time. Education Savings and Investment Alternatives In addition to the Plan, there are many other 529 Plans, including programs designed to provide prepaid tuition and certain other educational expenses, as well as other education savings and investment alternatives. These alternative programs may offer different investment vehicles and may result in different tax and other consequences. They may have different eligibility requirements and other features, as well as fees and expenses that may be more or less than those charged by the Plan. You should consider other investment alternatives before establishing an Account. No Guarantee of Admittance Participation in the Plan does not guarantee or otherwise provide a commitment that the Beneficiary will be admitted to, allowed to continue to attend, or receive a degree from any educational institution. Participation in the Plan also does not guarantee that a Beneficiary will be treated as a state resident of any state for tuition or any other purpose. Medicaid and Other Federal and State Benefits The effect of an Account on eligibility for Medicaid or other state and federal benefits is uncertain. There can be no assurance that an Account will not be viewed as a countable resource in determining an individual s financial eligibility for Medicaid. Withdrawals from an Account during certain periods may also have the effect of delaying the disbursement of Medicaid payments. Account Owners should consult a qualified advisor to determine how an Account may affect eligibility for Medicaid or other state and federal benefits. Suitability and Education Savings Alternatives Neither the Board nor the Program Manager makes any representations regarding the suitability or appropriateness of the Designated Portfolios or Individual Portfolio as an investment. Other types of investments may be more appropriate depending upon an individual s financial status, tax situation, risk tolerance, age, investment goals, savings needs, and investment time horizons of the Account Owner or the Beneficiary. There are programs and investment options other than the Plan available as education investment alternatives. They may entail tax and other fee or expense consequences and features different from the Plan including, for example, different investments and different levels of Account Owner control. Anyone considering investing in the Plan may wish to consider these alternatives prior to opening an Account. Differences Between Performances of Designated Portfolios and Underlying ETFs The performances of the Designated Portfolios will differ from the performances of the underlying ETFs constituting the Designated Portfolios. This is primarily due to differences in expense ratios and differences in the trade dates of Designated Portfolio purchases and the purchases of the underlying ETFs. The Designated Portfolios and the underlying ETFs have different expense ratios over comparable periods of time, so, all other things being equal, there also will be performance differences between the Designated Portfolios and the underlying ETFs. Performance differences also are caused by differences in the trade dates of Designated Portfolio purchases and the underlying ETF purchases. When you invest money in a Designated Portfolio, you will receive Trust Interests, i.e. the selected Designated Portfolio Units as of the appropriate trade date. (See CONTRIBUTIONS. ) The Trust will use the Account Owner s money to purchase the underlying ETFs to be held in the Designated Portfolio(s) which make up an Account Owner s Individual Portfolio. However, the trade date for the Trust s purchase of the underlying ETF typically will be one (1) business day after the trade date for your purchase of Trust Interests of the selected Designated Portfolio. Depending on the amount of cash flow into or out of the Designated Portfolio and whether the underlying ETF is going up or down in value, this timing difference will cause the Designated Portfolio s 35

40 Plan Risks performance either to trail or exceed the underlying ETF s performance. Differences Between Performances of Individual Portfolios and Designated Portfolios The performance of each Individual Portfolio will differ from the Designated Portfolios because it is a mix of one or more of the Designated Portfolios. Thus, an Individual Portfolio s performance may lag that of any one Designated Portfolio due to the lower performances of other Designated Portfolios included in the Individual Portfolio. Designated Portfolio Investment Risk Accounts are subject to a variety of investment risks that will vary depending upon the Designated Portfolio and the ETF underlying that Portfolio. APPENDIX A includes a summary of the investment objective and principal risks of each underlying ETF Investment. With respect to the underlying ETF, please remember that the information is only a summary of the main risks of each underlying ETF Investment; please consult each underlying ETFs prospectus and statement of additional information for additional risks that apply to each underlying ETF. Individual Portfolio Investment Risk Accounts are subject to a variety of investment risks that will vary depending upon the Designated Portfolio(s) that constitute an Individual Portfolio. (See Principal Risks discussions for each ETF underlying a Designated Portfolio in APPENDIX A - Profiles of Underlying ETFs. ) Moreover, it is possible that various risks of Designated Portfolios could combine to present greater risks than any single Designated Portfolio. 36

41 Other Information OTHER INFORMATION Arbitration The Participation Agreement and your investment advisory agreement with Wealthfront ( Wealthfront Advisory Agreement ) each contain a mandatory pre-dispute arbitration clause, which is a condition to investing in the Plan. Any controversy or claim arising out of or relating to the Plan Description or Participation Agreement, or the breach, termination, or validity of the Plan or the Participation Agreement, shall be settled by arbitration administered by the American Arbitration Association in accordance with its Commercial Arbitration Rules (except that if ABD, Wealthfront or WBC is a party to the arbitration, it may elect that arbitration will instead be subject to FINRA s Code of Arbitration Procedure), which are made part of the Participation Agreement, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. Electronic Communications and Disclosure Relating to Internet Access Wealthfront s automated investment service is a software-based financial advisor, which means you must acknowledge your ability and willingness to conduct your relationship with Wealthfront on an electronic basis. Under the terms of the Participation Agreement and the Wealthfront Advisory Agreement, you agree to receive all Plan Account information, Plan Account documents and any updates or changes to the same, by accessing your account on the Wealthfront website at (the Plan Website ) and Wealthfront s electronic communications. The signature for the Account Application, the Wealthfront advisory service, as well as all documentation related to the Plan and the Wealthfront advisory service are managed electronically unless noted otherwise on the Wealthfront website or within this Plan Description, the Participation Agreement or in the case of Wealthfront-only communications and documents, the Wealthfront Advisory Agreement. The Plan and your Wealthfront advisory relationship are designed so that you perform Account-related transactions and activity electronically via the Internet, including opening an Account and receiving documents. When you open an Account online, Wealthfront requires you to select a username and password. You can securely access and manage Account information including statements, transaction confirmations, and tax forms at the Plan Website once you have created an online user name and password and successfully fund the Account. You can access documents relating to your Account on the Plan website. The only way you can receive paper copies of Plan-related documents would be to print them from a computer. This Plan Description, the Participation Agreement, information concerning the Designated Portfolios and Individual Portfolios, and all required reports for an Account are available at the Plan Website. You should regularly visit the Plan Website. Wealthfront expects to post updated information concerning the Designated Portfolios and underlying ETFs and a revised Plan Description at least annually. These materials and this information also may be supplemented throughout the year and will be available on the Plan Website. Wealthfront may archive these documents and cease providing them on the Plan Website when they become out of date and, therefore, you should consider printing or electronically saving any information posted on the Plan Website before it is removed. Wealthfront may, from time to time, notify you by e- mail or other electronic means that Plan-related documents, including Account statements and transaction confirmations, have been delivered. However, this is no substitute for you regularly checking the Plan Website. You should consider printing or electronically saving any information that they may wish to retain before it is removed. You will be required to provide your username and password to access your Account information and perform transactions on the Plan Website. You should not share your password with anyone else. Wealthfront will honor instructions from any person who provides correct identifying information and is not responsible for fraudulent transactions it believes to be genuine according to these procedures. Accordingly, you bear the risk of loss if unauthorized persons obtain your username and password and conduct any transaction on your behalf or in your name. You can reduce this risk by checking your Account information regularly, which will give you an opportunity to prevent multiple fraudulent transactions. You should avoid using passwords that can be guessed and should consider changing your password frequently. Wealthfront employees or representatives will not ask you for your password. It is your responsibility to review your Account information and to notify Wealthfront promptly of any unusual activity. Wealthfront cannot guarantee the privacy or reliability of , so it will not honor requests for transfers or changes received by , nor will 37

42 Other Information Wealthfront send Account information through e- mail. All transfers or changes should be made through the Plan Website. The Plan Website uses generally accepted and available encryption software and protocols, including Secure Socket Layer, to prevent unauthorized people from eavesdropping or intercepting information sent by or received from Wealthfront. This may require that you use certain readily available versions of web browsers. As new security software or other technology becomes available, Wealthfront may enhance its systems. Continuing Disclosure To comply with Rule 15c2-12(b)(5) of the Securities Exchange Act of 1934 (the Rule ), the Program Manager, WBC and the Board, as appropriate, will make appropriate arrangements for the benefit of Account Owners to produce and disseminate certain financial information and operating data (the Annual Information ) relating to the Plan and notices of the occurrence of certain enumerated events as required by the Rule. They will make provision for the filing of the Annual Information with the Municipal Securities Rulemaking Board s Electronic Municipal Market Access system ( EMMA ). They will also make appropriate arrangements to file notices of certain enumerated events with EMMA. Creditor Protection Under U.S. and Nevada Law Bankruptcy legislation excludes from property of the debtor s bankruptcy estate certain assets that have been contributed to a 529 Plan account. However, bankruptcy protection in this respect is limited and has certain conditions. For a 529 Plan account to be excluded from the debtor s estate, the Beneficiary must be a child, stepchild, grandchild, or stepgrandchild (including a legally adopted child or a foster child) of the individual who files for bankruptcy protection. In addition, contributions made to all 529 Plan accounts for the same Beneficiary (i) less than 365 days before the bankruptcy filing, are included in the debtor s estate; (ii) between 365 and 720 days before the bankruptcy filing, are excluded from the debtor s estate to the extent that contributions do not exceed $6,425.00, as of April 1, 2016 (an amount revised every three years by the Judicial Conference of the United States); and (iii) more than 720 days before the bankruptcy filing, are fully excluded from the debtor s estate. Federal bankruptcy law permits a debtor to exempt certain specified assets from liability notwithstanding the assets being property of the debtor s estate. If the debtor is domiciled in Nevada (as defined under bankruptcy law), Nevada law provides that up to $500,000 of assets held in a 529 Plan account may be protected from creditors, depending on when such assets were contributed to the account and whether they are eventually used to pay qualifying higher educational expenses of the Beneficiary. However, under federal bankruptcy law, assets held in a 529 Plan account that are property of the debtor s estate are not exempt from debt for domestic support obligations. This information is not meant to constitute individual tax or bankruptcy advice, and you should consult with your own advisors concerning your individual circumstances. Independent Registered Public Accounting Firm The Program Manager has contracted with Thomas & Thomas LLP ( Thomas & Thomas ), an independent registered public accounting firm, which is an expert in accounting and auditing, to prepare annual financial statements for the Plan. The Plan s financial statements for the most recent fiscal yearend will be audited by Thomas & Thomas and will be available on EMMA. Custodial Arrangements The Bank of New York Mellon Corporation ( Bank of New York Mellon ) is the Plan s custodian. As such, Bank of New York Mellon is responsible for maintaining the Plan s assets. Tax Reporting ABD, the Program Manager, on behalf of the Board, will report withdrawals and other matters, as applicable, to the IRS, Account Owners and other persons, if any, to the extent required pursuant to federal, state or local law, regulation or ruling. Conflicts In the event of any conflicts, the Nevada statutes and the Code shall prevail over this Plan Description. Contact Information If you have any questions regarding the Plan or the details contained in this Plan Description, please contact Wealthfront at support@wealthfront.com or (650) or visit the Wealthfront website at Privacy Statements The Board of Trustees of The College Savings Plans of Nevada Privacy Statement The Board considers the privacy and security of the nonpublic, personal information it holds concerning each Account Owner and Beneficiary a top priority. 38

43 Other Information The Board also has received an assurance from the Program Manager that it is also a top priority for the Program Manager and Wealthfront. Specifically, the Board, the Program Manager and Wealthfront adhere to the following privacy policy for the benefit of current and past Account Owners and Beneficiaries: The types of nonpublic, personal information collected by the Board, the Program Manager and Wealthfront may include: o o o Information the you or the Beneficiary provides to the Plan on the application or otherwise, such as name, address, and Social Security number; Information the Board and the Program Manager may acquire as a result of administering an Account, and Wealthfront advising the Account, such as transactions (contributions or distributions) or Account balances; and Information from third parties, such as credit agencies. The Board, the Program Manager and Wealthfront will not disclose such nonpublic, personal information to anyone except as permitted by law. You should also carefully review the privacy statements of Ascensus College Savings and Wealthfront, which are referenced below. Privacy policies may be modified or supplemented at any time. Security The Board, the Program Manager and Wealthfront maintain appropriate physical, electronic, and procedural safeguards to protect this nonpublic, personal information about Account Owners and Beneficiaries. Ascensus College Savings Privacy Statement Under the terms of the Direct Program Management Agreement, Ascensus College Savings is required to treat all of your and your Beneficiary s information confidentially. Ascensus College Savings is prohibited from using or disclosing such information, except as may be necessary to perform its obligations under the terms of its contract with the Board, or if required by applicable law, by court order, or other order. Wealthfront and WBC Privacy Statement Under the terms of the Operating Agreement, Wealthfront and WBC are required to treat all of your and your Beneficiary s information confidentially. Wealthfront and WBC are prohibited from using or disclosing such information, except as may be necessary to advise its clients and perform its obligations under the terms of the Operating Agreement, or if required by applicable law, by court order, or other order. Investment Risk; No Guarantee Trust Interests are municipal fund securities issued by the Trust administered by the Board, which is chaired by the Nevada State Treasurer. When you contribute to the Plan, your money will be invested in Designated Portfolio Units of one or more Designated Portfolio(s). An investment in the Plan is not a bank deposit. None of your Account, the principal you invest, nor any investment return is insured or guaranteed by the Plan Officials, the federal government, the FDIC, or any other governmental agency. Investment returns will vary depending upon the performance of the Designated Portfolios in your Account. You could lose all or a portion of your investment. Interests in the Plan have not been registered with the SEC in reliance on an exemption from registration available for obligations issued by a public instrumentality or state. In addition, interests in the Plan have not been registered with any state in reliance on an exemption from registration available for obligations issued by an instrumentality of a state. Tax Considerations The Plan is offered to residents of all states. However, this Plan Description does not address state tax implications of the Plan. Individual Advice No investment recommendation or advice received by the Account Owner from Wealthfront or any other person is provided by, or on behalf of, the State of Nevada, the Board, the Plan, or ABD or any of its affiliates. Plan Description Information The information contained in this Plan Description is believed to be accurate as of the date hereof and is subject to change without notice. You should rely only on the information contained in this Plan Description. No one is authorized to provide 39

44 Other Information information that is different from the information contained in this Plan Description. This Plan Description does not constitute an offer to sell or the solicitation of an offer to buy, nor shall there be any sale of a security in the Plan by any person in any jurisdiction in which it is unlawful for such person to make such an offer, solicitation or sale. This Plan Description is for informational purposes only. In the event of any conflicts, the Nevada statutes and the Code, as amended from time to time, shall prevail over this Plan Description. Read this Plan Description carefully before you invest or send money. Representations Statements contained in this Plan Description that involve estimates, forecasts, or matters of opinion, whether or not expressly so described herein, are intended solely as such and are not to be construed as representations of facts. 40

45 Appendix A APPENDIX A: INVESTMENTS Please carefully read this APPENDIX A, as well as the entire Plan Description, for more detailed information about the Plan s investments and the Plan s Glide Path construction before you invest or send money. Investments Designated Portfolios and Underlying ETFs Wealthfront serves as your automated investment adviser. Under the Plan, Wealthfront constructs an Individual Portfolio for you using up to nine Designated Portfolios. Each of the Plan s Designated Portfolios consist of a low-cost, passive ETF, each tracking an industry-standard asset class index. Each underlying ETF also has a low tracking error to its benchmark as well as high liquidity. The Designated Portfolios are comprised of one low risk, shortduration U.S. Treasury Bill ETF and eight asset class ETFs (corporate bonds, Treasury inflation-protected securities (TIPS), emerging market bonds, real estate, dividend stocks, U.S. stocks, international stocks and emerging market stocks). For further information regarding each of the ETFs underlying the Designated Portfolios, see Profiles of Underlying ETFs below. With respect to the Plan s Designated Portfolios underlying ETFs, please remember that the information in this Appendix A is only a summary of the main strategies and risks of each Designated Portfolio s underlying ETF. Please consult each underlying ETF s prospectus and statement of additional information for additional strategies and risks that may apply to each underlying ETF. Asset Allocation and Portfolio Construction The Wealthfront asset allocation framework applies mean variance optimization ( MVO ) to identify diversified portfolios of investments that maximize the expected net-of-fee, after-tax, real investment return for a given level of expected risk, as measured by portfolio return volatility. MVO, which Wealthfront uses along with the Capital Asset Pricing Model ( CAPM ) to construct portfolios, provides a powerful mathematical framework for evaluating portfolio risk-return tradeoffs and is the foundation of Modern Portfolio Theory, a widely accepted framework for managing diversified investment portfolios. The current collection of mean-variance optimal allocations produced by this procedure is illustrated in Figure 1 below. Each of the allocations is assembled from up to nine of the Designated Portfolios listed in Fees and Expenses above. The figure displays a decomposition of the allocations into ETFs (left panel) and equity / bond / Treasury bills (right panel), in both cases, as a function of the targeted level of risk. Inputs for MVO include estimates of: (a) asset return volatility for each asset class; (b) expected returns for each asset class; and (c) estimates of correlation between asset classes, i.e., how performances of asset classes vary in relation to one another. Wealthfront measures asset return volatilities using an average of standard deviations obtained from long-term and short-term historical data and forward-looking implied volatility data from option markets. Wealthfront estimates correlations between asset classes using blended composites of realized correlation using both long- and short-term time intervals. Wealthfront uses the CAPM to derive baseline estimates of expected returns, which reflect expected returns in a market equilibrium based on systematic risk (as measured by market beta). Using the Black- Litterman framework, Wealthfront blends these baseline estimates with Wealthfront s long-term return expectations, which Wealthfront derives using data on interest rates, credit spreads, dividend yields, and other macroeconomic and financial market variables. Finally, Wealthfront calculates net-of-fee real expected returns by subtracting ETF expense ratios and expected inflation. Note that Wealthfront s estimates and expectations are simply estimates and expectations. Although they are based on a number of assumptions and methodologies that Wealthfront believes are reasonable, they may vary from actual circumstances and results and are not guarantees that any particular outcome will be achieved. Once invested, Wealthfront continuously monitors Accounts and uses trigger-based rebalancing, when necessary, to maintain optimal risk-return tradeoff as determined by MVO. A-1

46 Glide Path Construction A Glide Path represents a collection of mean-variance optimal asset allocations that automatically adjust over time to progressively decreasing levels of expected risk as the Expected Matriculation Date approaches, and determine how your Individual Portfolio will automatically be rebalanced over time. Glide Paths are based on the simple premise that the longer the investment time horizon you have, i.e., the more time you have to your Beneficiary s matriculation, the greater risk you can take to potentially increase returns. Each Account Owner s Individual Portfolio is matched to an optimized Glide Path based on the Account Owner s Risk Score, as determined by a Risk Questionnaire, and the Account Owner s starting point along the Glide Path is determined by the Expected Matriculation Date. Thus, two Account Owners with identical Risk Scores but Beneficiaries of different ages will transition along the same Glide Path, but start at different points reflecting the difference in their investment time horizons. The process for selecting an optimal Glide Path begins by specifying a collection of paths differing along three dimensions: 1. The risk of the initial allocation (i.e., the allocation at the inception of the Account); 2. The risk of the final allocation (i.e., the allocation at the Expected Matriculation Date); and 3. The initial time point at which the gliding is set to begin. Adjusting these three parameters tunes the expected returns and expected risks of each Glide Path. For example, increasing the riskiness of the terminal and/or initial allocations or beginning to glide at a later date will increase the overall expected return and risk of the Glide Path. These features interact with the Account Owner's contribution pattern to determine the overall Account accumulation. In particular, holding the present value of contributions fixed, accelerating (decelerating) contributions increases (decreases) the projected accumulation, because the asset allocations earlier along the Glide Path are projected to earn higher expected returns due to their higher expected risk. To characterize the statistical distribution of the projected Terminal Funding Ratio (i.e., ratio of Account assets to the present value of the total cost of college attendance at the time of the Beneficiary s matriculation), Wealthfront relies on a Monte Carlo simulation framework. Monte Carlo simulations rely on repeated random statistical sampling to obtain numerical results and are used to model the probability of different A-2

47 outcomes in a process that cannot easily be predicted due to the intervention of random variables. Model results are hypothetical, may vary from actual results and are not guarantees that any particular outcome will be achieved. The Monte Carlo simulation output provides a hypothetical assessment of the range of investment outcomes generated by the proposed Glide Path when combined with the Account Owner s planned contribution pattern. These simulations proceed as follows. First, for each month between the Account inception and the Expected Matriculation Date, Wealthfront simulates returns for the Designated Portfolios. Second, Wealthfront uses these simulated returns and the asset allocations specified by the Glide Path to obtain a simulated returns for Individual Portfolio for each period. The evolution of the Account s value is then determined by combining the sequence of simulated Individual Portfolio returns with the Account Owner s planned contributions. Finally, Wealthfront will use the Monte Carlo framework to simulate the evolution of the costs of college attendance, which are necessary to determine the Terminal Funding Ratio. By repeating these simulations, Wealthfront obtains a probability distribution of the Terminal Funding Ratio for each Glide Path / contribution pattern combination. Wealthfront chooses your optimized Glide Path to balance the probability of achieving a higher Terminal Funding Ratio with its uncertainty and shortfall probability. Specifically, the expected volatility of Glide Paths decreases as Risk Scores decrease. This procedure allows Wealthfront to uniquely match each of the 20 possible Account Owner Risk Scores to a corresponding optimal Glide Path. Although Account Owners answer a Risk Questionnaire influencing the selection of their optimal Glide Path, they do not have discretion to alter the underlying investment allocation of any Glide Path. An Account Owner may change their Risk Score at most twice in any year. Wealthfront Glide Path Characteristics The following table summarizes current risk characteristics of the optimal Glide Paths matched to each of the 20 possible Risk Scores. Volatilities and average allocations are reported as dollar-weighted averages over an 18-year investment horizon. These values are obtained by weighting the portfolio volatility and allocation in each month along the Glide Path by the average projected balance of the Account, which evolves due to realized market performance and equal monthly investor capital contributions. Risk Score is the score assigned to an Account Owner based on the Risk Questionnaire; a high (low) Risk Score corresponds to Account Owners with high (low) risk tolerance. Dollar-Weighted Volatility is the dollarweighted volatility of the Account Owner's returns along a given Glide Path, and is computed assuming the Account Owner makes a sequence of equal monthly dollar contributions and has an 18-year investment horizon. Average Equity Allocation reports the average share of the portfolio invested in equities along the 18-year Glide Path. The following asset classes (ETFs) are categorized as equity: US Dividend Growth Stocks, US Stocks, International Developed Stocks, Emerging Market Stocks, US REITs. Average Bond Allocation reports the average share of the portfolio invested in bonds along the 18-year Glide Path. The following asset classes (ETFs) are categorized as bond: Emerging Markets Bonds, US TIPS, US Investment Grade Corporate Bonds. Average T-Bill Allocation reports the average share of the portfolio invested in T-Bills along the 18-year Glide Path. The following asset class (ETF) is categorized as T-Bill: US Treasury Bills. A-3

48 Glide Path Risk Score Dollar Weighted Volatility Average Equity Allocation Average Bond Allocation Average T-Bill Allocation Glide % 79.0% 20.4% 0.6% Glide % 78.0% 21.5% 0.6% Glide % 74.8% 24.4% 0.9% Glide % 66.4% 32.2% 1.4% Glide % 59.6% 38.7% 1.7% Glide % 56.8% 41.2% 2.0% Glide % 54.3% 43.5% 2.2% Glide % 50.2% 47.0% 2.8% Glide % 47.7% 49.2% 3.0% Glide % 46.8% 50.2% 3.0% Glide % 43.1% 48.4% 8.5% Glide % 40.7% 50.0% 9.2% Glide % 38.2% 51.6% 10.2% Glide % 35.7% 53.0% 11.4% Glide % 32.9% 54.2% 12.9% Glide % 30.0% 55.1% 14.9% Glide % 27.0% 55.6% 17.4% Glide % 23.7% 55.0% 21.4% Glide % 22.7% 47.5% 29.8% Glide % 19.2% 45.4% 35.4% The Glide Paths have the following additional features that distinguish them from most other 529 Plans. First, unlike many other 529 Plans, your assets are not managed in a commingled fund structure. In a commingled fund structure, you buy a single fund, and A-4

49 you have exactly the same investment as every other investor. In the Plan, Wealthfront manages your Individual Portfolio separately and will allocate up to nine Designated Portfolios as prescribed by your Risk Score and your Beneficiary s Expected Matriculation Date. Second, asset allocations transition more smoothly than other plans. For example, the Plan s Glide Paths include up to 23 intermediate asset allocations over an 18 year investment horizon, varying based on the range of risk spanned by the initial and terminal allocations. The more granular transitions are illustrated below in the left panels of Figures 1a 1d. Finally, the Wealthfront 529 framework considers the impact of different contribution patterns on the Terminal Funding Ratio, specifically gradual funding versus superfunding (i.e., individual contributions up to five times the annual gift tax exemption per IRS 529(c)(2)(B)). Superfunding significantly improves terminal funding ratios over gradual funding on a risk - adjusted basis, assuming equal present value of contributions. Intuitively, superfunding accelerates contributions, such that a larger dollar value is invested over a longer duration of time. By considering these interactions Wealthfront is able to provide additional context for Account Owners regarding their ability to meet their college savings goals given various choices of investment and contribution patterns. The following illustrations are examples of Glide Paths and their respective asset allocations across the Plans three overall asset classes comprising T-Bills, Bonds and Equity and the nine Plan Designated Portfolios. A-5

50 Appendix A A-6

51 Appendix A Historical Investment Performance The Designated Portfolios and Glide Paths commenced operations in August 2016 so no performance information for the Designated Portfolios or your Individual Portfolio is available as of the date of this Plan Description. However, certain price and performance information of the Designated Portfolios will be made available on approximately 90 days after the Designated Portfolios and Glide Paths commence operations. Performance information for the Glide Paths will not be made available in this Plan Description; however performance information for your Individual Portfolio will be made available online immediately after the Designated Portfolios and Glide Paths commence operations by signing into your Account at The Designated Portfolio and Individual Portfolio performance information represents past performance and is no guarantee of future results. Investment returns and principal value will fluctuate, so Designated Portfolio Units, when sold, may be worth more or less than their original cost. For performance data current to the most recent month-end, which may be higher or lower than that cited, visit the Plan s website at The Plan s fiscal year runs from July 1 to June 30, which also is the Program s fiscal year. Performance information for the Designated Portfolios or Individual Portfolios should not be viewed as a prediction of future performance of any particular Designated Portfolio or Individual Portfolio. Moreover, in view of anticipated periodic revisions of allocations and possible changes in the underlying ETFs, the future investment results of any Designated Portfolio and Individual Portfolio cannot be expected, for any period, to be similar to the past performance of any underlying ETF. You can request a copy of the current prospectus, statement of additional information, or the most recent semiannual or annual report of any underlying EFT, and obtain performance information by visiting Vanguard s website at or by calling , and BlackRock s website at or by calling , as appropriate. Profiles of Underlying ETFs The following sections offer an overview of the key aspects of each of the underlying ETFs in the Plan s A-7